Page 1 of 39Version: February 22, 2010Summary of Comments on the Public Notice for the Proposed Information Collection for Steam Electric Power GeneratingEffluent Guidelines and EPA’s Response1CommentResponse60 Day Response Timea. 60 days to complete and submit the ICR (which requestsa high volume ofdata, high quality data, and historical data) is not sufficient and generallyunworkable. EPA should allow a minimum of 180 days to complete the survey.b. Many of the individuals that will be required to provide information holdpositions in which they perform activities essential tomaintaining and operatingout power plants. These individuals cannot be spared to do weeks or months ofwork on the ICR in a condensed time period. Instead, the will have to work theirschedules after certain duties have been completed.c. It is unreasonable to expect the “most knowledgeable person” or the “bestengineering estimate” to be available in the 60 day timeframe.d. Response time should be extended considering the government forms andother ICRs facilities are required to complete and submit.e. When EPA distributed the 316(b) survey in 2000, the responsetime was 90days to complete a survey that was less than one half the length of thisquestionnaire.f. Response time should be extended to accommodate smallutilities, co-ownedutilities, and companies that own multiple utilities.g. The general criteria for an extension request should belaid out. EPA shouldreply to extension requests in a fair and timely manner.a., b., and c.EPA has carefully evaluated the time required to complete the questionnaire,including reviewing comments on this topic, and continues tobelieve that 60days is sufficient time for completing the questionnaire.Should individualplants have extenuating circumstances that result in the needfor additionaltime, they can request an extension. EPA will consider each extension requeston a case-by-case basis. EPA is aware that, literally, the “most knowledgeableperson” may not be accessible for this questionnaire and has revised theinstructions to use the term “personnel knowledgeable in.”EPA disagrees withthe comment about “best engineering estimate.” The expectation is thatrespondents will make the engineering estimate as reflects the scope andcontext, including the time constraint of the ICR. Thisapproach actuallyprovides a reasonable degree of flexibility to respondentsand avoids imposingthe burden of collecting measurement data (other than leachate sampling) forthe express purpose of responding to ICR questions.d. and e.EPA has structured the questionnaire in a manner that allowsplants toefficiently compile the necessary information, including use of divisible partsthat can be distributed among plant staff. The time provided for responding toother surveys is not relevant to the time plants will need to complete this ICR.EPA notes that the steam electric questionnaire will bedistributed no earlierthan May 2010. Therefore, EPA does not anticipate any overlap withcollection activities such as EIA and FERC.f. EPA recognizes the concern raised but believes sufficient time is beingprovided to complete the survey. EPA has reduced burden for coal-fired plantsoperated by small entities by excluding them from Parts E,F, and G. Thequestionnaire is structured so that individual plants (i.e.,plant staff) will becompleting the survey, therefore the fact that plants may be co-owned or that1Question numbers referred to throughout this table refer to the 1stFRN version of the questionnaire.Page 2 of 39Version: February 22, 2010CommentResponsecompanies operate multiple facilities alone is not sufficient reason to provideadditional time for completing the ICR.g. See the response to a-f. EPA will not automatically grant extensions for thisICR. Each extension request will be considered on a case-by-case basis andEPA will respond in a timely manner. Until they receiveEPA’s response to arequest for additional time, plants should not delay responding to thequestionnaire.Defining the Scope of the ICRa. Facilities that do not possess a NPDES permit shouldnot be required torespond to the questionnaire.b. Facilities that have no discharges associated to theeffluent limitationguidelines should not have to respond to the questionnaire.Many of the questionsrequest analytical data but have no indication of finaldischarge. When thesedischarges go to evaporative systems or are recycled backinto the plant systemthere often are not adequate responses provided in the questionnaire.c. Zero liquid discharge facilities should not be includedin the scope of thisquestionnaire.d. Participants of the 2007Data Request for the Steam Electric PowerGenerating Industryshould not be included in the scope of this questionnaire.e. Consider “screener” surveys and/or questionnaires to gather information fromthe coal-fired power plant population.f. Plants that are closing and/or repowering in 2009 should not be included in thescope of this questionnaire.g. Small businesses should not be included in the scope ofthis questionnaire.a., b., and c.Information from plants that do not discharge wastewateris relevant to therulemaking process because it provide valuable insight toapproaches to reduceor eliminate pollutant discharges and it will be factored into the developmentand consideration of effluent guidelines options for otherplants. Therefore,these plants remain within the scope of this ICR.d. This ICR collects more broad operational data and financial data that werenot obtained by the 2007 data request and that is not obtainable through othersources; therefore, those facilities remain within thescope of thisquestionnaire. Also see Part A of the supporting statement.e.EPA did not elect to statistically sample a subset ofthe coal-firedpower industry for Parts A through D and I due to the number and typesof factors to be considered regarding FGD and ash operations, and thelimited data available for identifying these factors atpower plants to theextent necessary for establishing and defining strata for statisticalsampling, as well as the individual plants that populate eachsamplingstrata. Throughout the detailed study and during initial rulemakingactivities, stakeholders have stressed the need to evaluatehowvariability in equipment and operating practices between plants affectwastewater discharges. In addition, stakeholders expressedconcernover properly accounting for the financial conditions at eachplant,considering ownership of individual generating units including, in anumber of instances, multiple partial owners. EPA considered anapproach that would issue a screener survey followed by amorePage 3 of 39Version: February 22, 2010CommentResponsedetailed questionnaire to selected plants, but determined that the widerange of variables to be evaluated would still result in a wide crosssection of the industry being selected for the detailed questionnaire.Despite the commenter’s suggestion to issue a screener, itshould benoted that the comment identified more than sixty factors that shouldserve as strata for statistically sampling plants; this is withoutaccounting for financial strata criteria and other technical factors ofinterest. Given this situation, a screener questionnaire would be ratherextensive itself, and in the end possibly would not substantially reducethe number of coal-fired plants that would receive thedetailedquestionnaire. The types of operations and the associated processwastewaters can change from facility to facility dependingon factors,such as the type of coal burned, air pollution controls in place, type ofwet FGD absorber design, FGD wastewater treatment, type of ashhandling system, ash pond management, type of cooling water system,and the water source. Considering the large number of characteristics tobe evaluated and the limited data currently available, EPA willdistribute Parts A through D and I of this questionnaire toall coal-firedpower plants.f. EPA has revised the questionnaire so that facilities that are permanentlyretired or will be permanently retired by December 31, 2011 will have tocomplete only a few questions at the beginning of the survey. However, plantsthat are repowering and will resume operating must completethe survey.g. EPA will include small businesses in the scope of thisquestionnaire toobtain information necessary to understand their operations and how changesimposed by revised effluent guidelines would affect them operationally orfinancially. However, to reduce burden imposed on these entities EPA isexcluding coal-fired plants operated by small entities fromresponding to PartsE, F, and G.Notification of the ICRa. EPA should provide the list of respondents prior to the mail out of thequestionnaire.a. EPA does not intend to publish the list of facilityrecipients prior to mail ofthe questionnaire because doing so could potentially jeopardize CBI responses,or force EPA to aggregate CBI (to prevent revealing CBI) in such a mannerPage 4 of 39Version: February 22, 2010CommentResponseb. EPA should notify trade associations and industry of any changes made to thequestionnaire (from the 1stFRN Draft) prior to the 2ndFRN publication.that makes it more difficult for the public to view details of EPA’s regulatoryanalysis..b. EPA has continued outreach with industry and and other stakeholders todiscuss plans and potential ICR revisions, as appropriate.A revisedquestionnaire will be published as part of the 2ndFRN and the public will thenhave an additional opportunity to review and submit commentson the ICR.Distribution of the ICRa. If the distribution of the questionnaire happens in the May-June 2010 period itwould be very difficult to spend 200 to 500 hours answering thequestionnaire foreach facility. Facilities also have to file routinereports such as DMRs and TRIreports by July 1st. Suggest distributing the questionnaire after July 1st.b. Delay the ICR until January 2011 to reduce burden on respondents, as well asincrease the utility of the ICR.c. There should be some consideration given, when distributing the ICR, to theother ICRs that facilities will be required to respondto.d. EPA should delay the distribution of the ICR until after the pending CCR Rule(specifically questions and requirements regarding ash handling and leachatesampling). It is likely that the CCR rule will have a significant impact on cementmanagement practices for fly ash, bottom ash, FGD scrubber solids, etc. Whenthe CCR rule is finalized, the information for Part B,C, D, and G could belargely obsolete.a., b., and c.EPA is aware that the questionnaire may be distributed at atime when plantsare engaged in other data collection and reporting efforts. However, EPArecognizes that some of these efforts are year-roundand/or recurring activitiesfor which plants are already staffed, and that it is impossible to avoid all otherdata collection efforts. In addition, this ICR will occur after plants havecompleted efforts for EIA and FERC, and much of the Utility MACT ICR.The proposed effluent guidelines are scheduled for publication in 2012. Inorder to meet this deadline, data collection must occurby mid-2010.d. EPA has made every effort to reduce or eliminate overlap of industry datacollected, and to tailor this questionnaire to informationnecessary to reviseELGs. Although EPA recognizes that future changes may occur in thehandling of CCR, the data requested on current and past operations will still beuseful in evaluation technologies for control of wastewater discharges. Alsosee response to comments for Part C and G.Development of the Questionnairea. In developing this ICR, EPA has not been willing to discuss industry concernsand adopt suggestions as EPA has been in the context of other ICRs.b. This ICR attempts to better understand power plant operations with regard towater discharges for a number of different plant designs.However, based ontrade association experience, the chemistry of trace elements and theirpartitioning to the water stream is not well understood,and the existing data willnot be sufficient in terms of quality and breadth to allowAgency to project waterimpacts.a. EPA encourages industry input and has consistently kept an opendoor tofacilitate communications over the course of the deatailed study and for thisrulemaking, including the ICR development. See the docketfor informationabout outreach and technical discussions with industry andother stakeholders.b. EPA feels that the questionnaire requests appropriatecurrent and planneddata to understand current and future discharges in the industry. EPAencourages discussions with industry on content of and ways to continuallyimprove the questionnaire. In addition, EPA invites stakeholders to provideadditional data they believe EPA needs to project waterimpacts.All Parts/Definitions/TermsPage 5 of 39Version: February 22, 2010CommentResponsea. EPA should prepare a list of definitions/glossary for terms found within theICR.b. The Utility Water Act Group (“UWAG”) submitted a letter to EPA requestingthat EPA provide definitions for several undefined terms used throughout thedraft questionnaire. EPA should formally respond to the request.c. To ensure consistent understanding by both EPA and theindustry, it isimperative that EPA make its glossary available for public comment beforesending the proposed ICR to OMB for review.d. EPA has failed to provide adequate notice because of thelack of a glossaryand incomplete nature of the draft questionnaire.e. Request for “planned” activities will likely yield inconsistent results. EPAneeds to define “planned” and “future” in both scope and scale.f. In order to facilitate completion of the questionnaireas soon as possible, adetailed table of contents is needed.a., b., and c.EPA prepared a glossary of terms for the questionnaire and consideredUWAG’s recommendations in developing the glossary. EPAshared this draftglossary with stakeholders in advance of the second FR notice and receivedextensive feedback from industry. These suggestions were considered inrevising the glossary, which is included in the currentversion of the ICR.d. EPA disagrees that the Agency failed to provide adequatenotice. EPA alsodisagrees that because a separate list of definitions was not provided with thedraft questionnaire, that it is not possible for the publicto provide meaningfulcomment. Many of the terms were defined within the instructions andquestions of the survey.e. EPA has revised the questionnaire to more specificallyinstruct facilities onthe request for “planned” and “future” activities.f. EPA will include a Table of Contents in the questionnaire.Request for 2008/2009 Dataa. Requesting 2008 data as the most recent year would allowcompanies to startgathering information sooner. 2008 data is already available and given theeconomic downturn late in 2008, the argument could be made that 2008 was amore representative year for facilities than 2009.a. EPA has minimized the specific request for 2009 data tothe extentnecessary. In many instances, EPA does not limit therequest to a specific yearand instead asks for data that represent “normal operations”. The commentpage provides an opportunity to identify any atypical data. EPA will ask for2009, where appropriate, to establish consistency amongresponses.Overlap with Existing Dataa. A number of questions request information which appears tobe available viathe Energy Information Administration (EIA)/Federal Energy RegulatoryCommission (FERC) databases. Where possible, utilization of existing resourceswould reduce unnecessary efforts by the Agency and respondents.b. Under section 3506(c)(3)(B) of the Paperwork Reduction Act, EPA mustcertify to OMB that the information sought under an ICRis not unnecessarilyduplicative of information otherwise reasonably accessible to the agency.Commenters believe that EPA's proposed ICR does not meetthis standard.Questions in the proposed ICR overlap with information thatis proposed to becollected by EPA under the ICR for developing MACT standardsfor coal- andoil-fired electric utility steam generating units (the“Utility MACT ICR”). Thus,the Office of Water must use information that will becollected by the Office ofa. EPA has completed a thorough review of the entire questionnaire forpotential overlap with other sources (e.g., EIA, FERC).Following this review,EPA deleted or revised certain requests or otherwise attempted to minimize reproviding the exact information in more than one report (except where neededfor identification purposes). Specific overlap has been addressed in the specificcomment responses for each part.b. EPA has completed a thorough review of the entire questionnaire foroverlap with other completed or ongoing ICRs (including theUtility MACTICR and the ORCR data). Where possible, EPA has deletedor revisedquestions to minimize or eliminate overlap. Specific overlap has beenaddressed in specific comment responses for each part.Page 6 of 39Version: February 22, 2010CommentResponseAir and Radiation as well as information that has already been collected by theOffice of Solid Waste and Emergency Response, insteadof collecting duplicateinformation.Electronic Format for the Questionnairea. In a recent EPA-sponsored conference call, EPA personnel asked forrecommendations for software to be used for the electronic version of the ICR.After review, EPA should use MS Excel.b. EPA should thoroughly test the electronic version ofthe questionnaire beforerelease.a. and b.EPA is using MS Excel as the format for the electronic questionnaire. Thisformat is being distributed as part of the 2ndFRN to gather additional input onformat and allow stakeholders the opportunity to test itbefore distribution. Inaddition, EPA has conducted initial testing and will continuetesting thequestionnaire prior to its distribution. This electronicmethod was created tominimize burden on the industry and ensure efficient processing of thecollected data.CBI Justificationsa. EPA has made the process for claiming information asCBI extremelyburdensome. The request to provide justifications departs significantly fromprevious ICRs. EPA should work the industry to designate portions or evencomplete section CBI.a. EPA recognizes that supplying justifications for CBI marked informationmay impose burden unnecessarily on the industry. Therefore, answers can bemarked as CBI according to practices familiar to theindustry. A checkbox forthe question will be marked and no justification at the time of submittal willbe required.Certification Statementa. EPA's proposed certification statement, requiring "best knowledge and belief'that the information is accurate, is inappropriate foran ICR of this complexity. Incontrast, the proposed MACT ICR does not include a general certificationstatement. (There are certifications associated withsome of the individualquestions.)a. Respondents should certify that the requested information is accurate to the"best of their knowledge and belief" given the time andcomplexity constraintsof the questionnaire. The certification language is typicalfor EAD programsand is appropriate for a data collection such as this.Request for Cost Dataa. Providing capital cost estimates of past projects,many by engineeringjudgment, will stretch the usefulness of the resulting data,but coming up with abreakdown of O&M costs associated with specific plant operations (for examplethe fly and bottom ash handling costs in Part C) or perpond/impoundment (perQuestion D54) will result in data of very limited value.b. Some capital costs are over 30 years old and may be estimates. Should 30-yeardollars be used or should the dollar estimates be escalated forward?a and b. EPA does not agree that the requested O&M data will be of limitedvalue. These data are necessary to evaluate potential technology options andthe impacts that new pollution control requirements may have on plants. EPAhas limited the request of O&M costs for ponds/impoundments,landfills, andash handling systems to those installed after January 1,1985 to reduce burden.Respondents should answer these questions with the bestavailable informationand use the comments page to call attention to any estimates or assumptionsthat may have been made. Respondents should answer questions referring tocapital costs with the best available information andspecify the year basis ofthe provided costs. EPA has limited the request of capital costs forPage 7 of 39Version: February 22, 2010CommentResponseponds/impoundments, landfills, and ash handling systems to those installedafter January 1, 1985 to reduce burden. No inflation costs need to be appliedto the costs provided by respondents.Burdena. EPA’s burden estimate is too low, especially for utilities with multiple plantsites. The amount of information called for seems over burdensome in that it isnot clear that the amount of requested detail is needed.b. Companies have noted that completing the questionnaire will take on the orderof five to ten full-time staff several months per facility, a burden that is verydifficult to sustain. EPA needs to provide a more realistic burden and look forways to reduce the burden.c. EPA consistently states that the survey is dividedinto sections to reduceburden, saying that no facilities will have to complete all sections. All coal plantswill have to complete at least four, one third will have to complete all except,obviously, the nuclear section. This does not reduce the burden.d. EPA’s average burden estimate of 205 hours is extremelyunderestimated anddoes not account for different facilities being subjectto different questionnairerequirements or any first level coordination. This estimate should at least bedoubled for coal-fired power plants.e. Nowhere in the calculation of the responded time burdendoes EPA accountfor facilities having multiple units.f. EPA could reduce the burden by eliminating questions unrelated to dischargesto “Waters of the United States”.g. Eliminate questions requesting capital costs in Parts Cand D for olderinstallations to reduce burden.h. EPA’s estimate of total burden is not clear and unable to be replicated.i. EPA’s labor costs and time estimates are questionable.a. and b.EPA has reviewed and considered all comments received regarding the 1stFRN burden estimate. EPA has revised the burden estimate,incorporatingcomments from the industry and revisions made to the questionnaire. EPA hascarefully reviewed and revised the questionnaire to eliminate any burdensomerequests that are unnecessary. See Part A of the supporting statement forinformation on why the data are being requested.c. and d.EPA reviewed the questionnaire and comments to revise the hourly burdenestimate, taking into account some time for first level coordination. EPArecognizes that the calculated average burden differs according to differentfuel segments of the industry. EPA will estimate a burdenfor each segment ofthe industry to come up with a more accurate average burden corresponding toa specific fuel type.e. EPA revised the burden to account for all plants, units, wastewater systems,ponds and landfills, and wet/dry FGDs. The revised SupportingStatement,published with the 2ndFRN, explains the number of respondents estimated forrevising the burden.f. The questions included in the ICR are relevant to “water of the UnitedStates” in that they characterize operations that generate wastewater and howthose wastewaters are managed, or identify practices thatavoid generatingand/or discharging wastewater. As part of the rulemaking,different regulatoryoptions will be considered, this information is requested to address each optionaccordingly and make informed decisions about potential revisions to theELGs.g. EPA has limited the request of capital and O&M costs forponds/impoundments, landfills, and ash handling systems to those installedafter January 1, 1985 to reduce burden.h. EPA revised the Supporting Statement so that the calculated burden is clearPage 8 of 39Version: February 22, 2010CommentResponseand able to be replicated.i. EPA will adjust labor rates by 30% to account for employee overhead andbenefits. The time estimates were reevaluated for therevised ICR, includingconsideration of comments on this topic.Supporting Statementa. Page one states, "... determined that significant amountof the toxic pollutantloadings discharged to surface water by point sources." appears not necessarilyfact based, and is not supported by references. Recommend changing wording orprovide an example/proof for the statement that it was "determined thatsignificant amount of the toxic pollutant loadings dischargedto surface water bypoint sources."b. Support statement language regarding EPA seeking information on, "candidatepollution control technologies" to meet the effluent guidelines approach, appearsto be open to candidate technologies regardless of theirpoint of development.EPRI is concerned that technologies not yet proven on specific power plantwastewater at a full-scale should be noted as such. Reference needs to be made to"demonstrated controls" with respect to "candidate pollution controltechnologies" to meet the effluent guidelines approach.a. EPA refers to the findings of theSteam Electric Power Generating PointSource Category: Final Detailed Study Report(EPA 821-R-09-008) to supportthis statement. See the report for information supportingthese findings.b. EPA plans to use the information collected by the questionnaire andadditional research to consider and review candidate pollution controltechnologies. EPA will evaluate all aspects of potential control technologies,including their technical feasibility, whether they are demonstrated, and theireconomic affordability, before using them as a basis for revised ELGs. It is notnecessary for a technology to be proven at full-scale oron a specific powerplant wastewater for it to be considered as a basis for revised ELGs.Front Mattera. Page iii states “Extension requests will be evaluatedon a case-by-case basis.Submittal of an extension questionnaire to EPA...” The word “questionnaire”should be changed to “request” in the second sentence of thisparagraph.b. Page ii states “Each part should be completed by theperson(s) mostknowledgeable about the information requested.” Throughout theQuestionnaire,references to “persons most knowledgeable” should be changed to “qualifiedpersonnel” consistent with the certification statement.Given the very shortresponse time for the Questionnaire, it is unreasonableto expect that the mostknowledgeable person will always be available or could even be immediatelyidentified and assigned to the appropriate topics. All companies will needmultiple personnel to respond to the questions. By the time the Questionnaire iscirculated to all personnel who will need to contribute to the answers, asignificant portion of the 60-day period will have alreadypassed. TheQuestionnaire does not provide adequate time for intra-companya. EPA incorporated this change.b. See response above for “60 Day Response Time.”c. EPA added a glossary that defines all key terms found in the questionnaireand added a list of acronyms at the end of the front matter. See response abovefor “All Parts/Definitions/Terms.”d. See response above for “60 Day Response Time.”Page 9 of 39Version: February 22, 2010CommentResponsecommunications and quality assurance steps.c. EPA should provide definitions of key terms. Definitions of key terms,according to the instructions, are supposed to be “at theback of thequestionnaire” but are not attached. Neither is the promised list of acronyms andmeasurement units. Among many other undefined terms, EPAshould define thefollowing bold, italicized terms: plant-p. vi; wastewater treatment, p. vi; pollutionprevention, p. vi; best management practices, p. vi; permanently, p. E-5;temporarily, p. E-5; pond/impoundment, p. E-5; disposal, p.E-5.d. Although the instructions provide for individual extensionsto be decided on acase-by-case basis, and provides a 21-day period for filingan extension request,EPA does not specify how quickly it will act on those extension requests.Requests that EPA agree to respond to extension requests within one week afterelectronic receipt of the request. Also, EPA should provide some general criteriathat will be considered in granting extension requests.Part A/Steam Electric Power Plant Operationsa. Commenters believe a question should be added, so thatif a facility does notdischarge wastewater (i.e., do not possess a NPDES permit), then the facilitywould not be required to complete the questionnaire.b. Commenters believe that Q. A1-2 through A1-5 should berevised to requirethe submission of a single contact name due to the complexity of the questions inthe Questionnaire. This person would be responsible for contacting additionalindividuals for responses to additional questions posed by EPA.c. Commenters think Q A1-6 should to be more specific. They ask if the unit hasnot generated electricity during the 2009 calendar year,would the answer be no.d. In Q. A1-9, commenters ask EPA to provide clarification regarding whatconstitutes "Distributed NOT for sale" to ensure consistency in responses. Theyare uncertain if it refers to power used for station service.e. In Q. A1-11, commenters ask what standard applies for judging whether theprimary purpose of the plant is generation of electricity.Does it mean 50% ormore of the profits are from electricity generation?f. Commenters believe the information requested should belimited to 2007through 2009 in Q. A1-15. Requiring information from 2005 through 2009 isa. EPA does not agree. See response for “Defining the Scope of the ICR.”b. EPA requests a primary and secondary contact for both the technical andeconomic data for cases when one of the contacts mayleave the company.Additionally, the contacts for economic and technical information are oftendifferent. If the plant determines the same contact canprovide both economicand technical information, they can answer accordingly. However, bothprimary and secondary contacts are still required.c. EPA changed the wording to ask if the plant has the potential (i.e.,equipment available on site) to generate electricity from a steam electricgenerating unit.d. EPA removed the “Distributed NOT for sale” response option. If the plantis generating power for the distribution and use off site, the plant will select“Other” and provide a description.e. EPA defines primary purpose as “the predominant sourceof revenue andprincipal reason for operation.”f. EPA reduced this request to 2007-2009, and intends to obtain data on 2005and 2006 from EIA, as available.Page 10 of 39Version: February 22, 2010CommentResponseoverly burdensome and is unlikely to provide information that is morerepresentative.g. Commenters ask EPA to confirm that Q. A1-18 requests information forpermits associated with wastewater or stormwater discharges from industrialactivities and does not include permits required for construction of wastewaterand/or sanitary sewage facilities; erosion and sedimentcontrol permits associatedwith construction activities; temporary permits, generalpermits for hydrostatictesting water, water obstruction and encroachment permits and/or waterallocation permits. Furthermore, commenters believethat EPA should delete therequirement to include pending permits. Pending permits havenot been issued asyet, may be changed prior to issuance in final, and often do not have permit IDs,approval dates, or expiration dates. Additionally, commenters ask why EPAneeds information on the plant’s RCRA, air, and UIC permits for the purpose ofsetting effluent guidelines.h. Limited or zero discharge facilities may not have receiving waters for certaindischarges to include in Table A-3.i. Commenters believe that EPA should clarify that thesurface waters at issue arethose that are waters of the United States or watersof a State and not watersoutside the jurisdiction of EPA and a State. As Q. A1-19 is currently worded,respondents may believe they need to identify non-regulated on-site waters suchas private ponds or water bodies that are part of the wastewater managementsystem. In addition, it is assumed that plants discharging tocooling ponds thatare not Waters of the U.S. do not need to answer thisquestion. Additionally,“Reservoir” should be added as a possible response under typeof receivingsurface water in Table A-3.j. Throughout Part A, EPA uses the term “planned.” Commenters ask EPA todefine this term to ensure consistent responses. Theysuggest a short-time framesuch as within the next 2 years.k. Many power stations utilize small sediment traps along access roads, haulroads, soil borrow areas, closed landfills, etc. to minimize the quantity ofsuspended solids to receiving streams. Pennsylvania, along with other states,broadly defines these same terms. Therefore, commenters request that EPAdefine the terms ponds, impoundments, storage, disposal, process wastes,g. EPA clarified in the instructions for Table A-2 thatQ. A1-18 should onlycover permits associated with industrial activities and that permits required forconstruction of wastewater and/or sanitary sewage facilities; erosion andsediment control permits associated with construction activities; temporarypermits, general permits for hydrostatic testing water,water obstruction andencroachment permits and/or water allocation permitsare not required. EPAadded an additional column in Table A-2 asking plants if they have a pendingpermit under development and revised the instructions so that plants will notneed to provide the ID numbers and dates associated withthe pending permits.Information in permits not related to water such as RCRA, air, and UICpermits will provide EPA with the information needed soit can obtain thepermits, if necessary, to evaluate potential waste streams that may be generatedfrom other process operations associated with the requirements for thosepermits. For example, these permits will include information on carbon captureand storage systems and other technologies, which generate wastewater ofinterest.h. EPA revised Table A-3 to request this information on an outfall basis and ina question format. EPA clarified that plants should skip the section collectingoutfall information if the plant does not have a NPDES permit (i.e., nooutfalls).i. EPA revised Q. A1-19 to request information on the receiving water for eachoutfall designated in the plant’s NPDES permit. EPA added “Reservoir” as aresponse option for the type of surface water.j. EPA agrees that it would be useful to define a timeframe for reportingplanned systems, but disagrees that "planned" should be limited to the next twoyears. EPA established appropriate timeframes for specific questions in thequestionnaire.k. EPA defined the terms "pond/impoundment", "process wastewater", and"residue" in the glossary of the questionnaire. EPA does not believe definitionsare required for “storage,” “disposal,” and "by-products."The questionnairedoes not require plants to report information on sedimenttraps.l. The term "effluent point" has been changed to "pond outlet," which isdefined as "the point at which the pond/impoundment releases water to anotherpond/impoundment, surface water, or other process." Thequestion alsoPage 11 of 39Version: February 22, 2010CommentResponseresidues, and by-products and clarify if sediment traps are included within thesedefinitions.l. Commenters ask EPA to clarify in Q. A1-20 whether the effluent point is thepoint at which the effluent is discharged to a water ofthe United States or a waterof the State or whether it includes internal discharges betweenponds/impoundments. Many ponds have outlet structures that lead to additionalwater treatment and then an effluent discharge; it is unclear under the existinglanguage whether a pond outlet would be considered an effluent point. “Effluentpoint” should be defined as that point where the treatedeffluent (pond orotherwise) discharges to the receiving water as defined in the applicable NPDESpermit.m. Commenters believe “landfills” should be defined.n. In column 5 of Table A-4 in the heading, commenters ask what does EPAmean by “is leachate collected.” Commenters state thatleaks fromponds/impoundments are not leachate. Commenters ask why does EPA needinformation on retired and closed ponds/impoundments and believe EPA shoulddefine “closed” and “retired.”o. Commenters think that Table A-5 needs a separate column forwater/wastewater treatment chemicals and/or metals and should include columnsfor metal cleaning wastes, coal pile runoff, and low volume wastes. Additionally,the instructions for Table A-5 and Table A-7 should clarify that respondents donot need to report de minimis or incidental amounts of wastes stored or disposedof in ponds/impoundments or landfills.p. Commenters state that the heading in column 3 of Table A-6 is wrong. This isthe table for landfills, not ponds/impoundments.q. Q. A1-22 requests latitude and longitude of the site. Commenters ask EPA toclarify the location at which the geographical coordinates of the plant should beidentified (e.g., the center of the plant, the entrancegate, etc.).r. In Q. A1-23, commenters think that the word “available”is ambiguous andneeds clarification. Land at some facilities could be made available for processequipment, treatment systems, etc. but only after extensive site work and gradingis performed. Distance from the plant and limitations posed by existing structuresalso affect availability but could be overcome at greatexpense. Most electricgenerating stations have extensive arrays of buried electrical lines and pipes thatclarifies that emergency outlets should be used for ponds with no regulartransference to another location.m. EPA defined the term “landfills” in the glossary ofthe questionnaire.n. EPA revised the definition of the term “leachate” toinclude leakage, leak,seepage, leachate collection, and leak detection sources.EPA believes thatinformation on closed and retired units is necessary because retired and closedunits have a potential to impact surface waters. For example, knowing whetherthe pond is lined is relevant whether the pond is operational or retired. EPAdoes not agree that “closed/retired" requires a definition.o. Plants are not required to report water/wastewater treatment chemicalsand/or metals in this table. EPA revised Table A-5 to include not only solidwastes, but also process wastewaters that are stored,treated, and/or disposed ineach pond/impoundment unit. EPA disagrees that certain wastes should not berequired to be reported in Table A-5 and Table A-7. Therefore, no changeshave been made.p. EPA corrected the heading in column 3.q. EPA revised this question to allow respondents to skip ifthey alreadyreported their coordinates to EIA on U.S. DOE/EIA Form-860 (2007),schedule 2, line 6. EPA did not clarify the location for the coordinates so thatrespondents could use their EIA responses (EIA does not specify the locationfor the coordinates).r. EPA has removed Q. A1-23 from Part A.s. EPA revised the instructions of Q. A1-24 so that plants will only need toprovide aerial photographs or maps, but do not need to identify variousinformation on the map (e.g., wetland areas, surface waters bordering site).t. EPA revised the instructions of the water balancediagram to reduce theburden on plants. The instructions now specify that plantsare allowed to usewater balance diagrams from previous years as long as they are stillrepresentative of current operations. In addition, EPA revised the instructionsto request that plants report the process operations at the unit level instead ofrequiring them to report and present all the equipment that is used in each unit.EPA has developed a destinations table located in the “CodeTables” tab at theend of the part, which provide more general destinationoptions.Page 12 of 39Version: February 22, 2010CommentResponseseriously complicate development activities. Additionally, most power plants arelocated near waterways with associated wetland areas.Commenters believeavailable land should be defined as upland areas with no or minimal existinginfrastructure and within a certain distance (i.e. 500’)of existing units.s. Commenters believe that the maps requested in Q. A1-24 will be very timeconsuming to prepare. This is overly burdensome. EPA should use existingpublic sources of information. Some companies would need toinclude withinthe property map a map of the facility’s reservoir (ranging in the thousands ofacres) because the reservoir part of the facility isproperty. Additionally, if thereis no discharge to wetlands, there is no reason to include them in thequestionnaire.t. Commenters believe preparing the water balance diagram requested in Q. A1-25 will be very time consuming and burdensome. Much of theinformationrequested (e.g., flows) does not exist for many of the streams EPA has indicatedmust be included on the Block Flow Diagram. EPA should not expect the waterbalance diagram to actually balance. In addition, diagrams are typically preparedby our environmental consultants when preparing permit applications, so nonewill contain data from 2009. As a result, subcontractors will be required tocomplete this activity putting more burden on the plant. In addition, the averageannual flow rates should be estimates; otherwise it maybe very difficult toensure the flow rates match information in Table A-8. The final destinationsindentified in the block diagram requested in Q. A1-25 should begeneral (e.g.,off-site disposal, off-site reclamation, etc.) and notspecific (e.g., the names ofoff-site locations that receive materials).u. Commenters think that the purpose of Table A-8 is unclear. Why does EPAneed sludge data for a water balance table? Also, does the “solids or sludge”column refer to tons of sludge or tons of water in the sludge? Also, the volume ofsludge or solids should be an average because the amount of sludge or solidsproduced on a daily basis can vary greatly over time. The terms “source water”,“process wastewater”, “treated wastewater”, “solids”,“sludge” used in Table A-8should be defined.v. The “Date of Retirement or Expected Date of Retirement” column in Table A9 implies that any retired unit should be described. Responders may interpretrequirement of how far back to report differently. Becauseretired plantsgenerally do not generate wastewaters for discharge, thisinformation requestappears to be excessive and would not yield useful informationabout theu. EPA deleted Table A-8 from the Questionnaire; therefore, clarification isnot needed. EPA deleted Table A-8; however, EPA has included definitions ofthe following terms in the glossary: “process wastewater”, “treated”, and“sludge” in the glossary of the questionnaire.v. EPA removed the “Date of Retirement or Expected Dateof Retirement”column from Table A-9, because this information can beobtained from theMACT ICR.w. Although EPA removed the need to report type of boilerin Table A-9, EPAadded "Pressurized water reactor," “Boiling water reactor,” and “Pressurizedheavy water reactor” as response options in the "Typeof Boiler or Reactor”column for Table A-10. EPA also defined the terms "cycling unit" and"intermediate unit" in the glossary of the questionnaire.x. Cooling system data are not provided in Table A-9. EPA assumed thecommenter was referring to Table A-11. Table A-11 isalready designed toallow multiple cooling systems at the same plant to bereported, by designatinga cooling system in each row and indicating what units areserviced by thesystem. Respondents should not use the 316(b) designations for the ICR.y. EPA revised Table A-11 so that plants can specify more than one biocideand more than one active ingredient can be added per biocide.z. EPA revised the “Average Amount of Wastewater Generation/Blowndown”and “Typical Duration AND Frequency of Generation/Blowdown”columns inTable A-11 by changing "average" to "typical" in both columns.aa. EPA revised Table A-11 by changing the fourth column header "Type ofBiocide Used in Cooling System" to "Chemical Additives Added to theCooling System and Make-up Water System."bb. EPA revised Table A-11 to include only condenser cooling systems.cc. EPA deleted the request for copies of the reports and calculation sheets.EPA refers to any type of monitoring used to demonstratecompliance. Plantsmay provide further explanation in the comments page, as necessary. EPAassumes that this question actually applies to A1-29 (Table A-11). Coolingtower blowdown is relevant to the revision. Blowdown is currently coveredPage 13 of 39Version: February 22, 2010CommentResponseindustry as a whole. Furthermore, personnel familiar with retired units are oftenretired as well or no longer have detailed knowledge about older retired units.Lastly, information about older retired units is oftenarchived and/or is notreadily available. Therefore, EPA should consider requesting information forunits retired since a set date.w. In Table A-9, EPA should include “nuclear” as an option in the “type ofboiler” column. EPA provides definitions for “peaking unit”and “baseloadunit”, but also needs to define “cycling” and “intermediate.”x. Commenters ask how should multiple cooling systems atthe same facility bedistinguished in Table A-9 and also should the designations used for the 316(b)questionnaire be used for this questionnaire as well.y. For each cooling system there is only space for listing one biocide used in asystem in Table A-11. Commenters state that table A-11should be revised toallow for the identification of more than one biocide and more than one activeingredient per biocide.z. Table A-11 requests information in a manner that is certain to produceresponses that may not be comparable to other responsesor may not meet theagency's intentions with regards to the requested information. The fifth columnfrom the left asks for "Average amount of wastewater generated/blown down."EPA needs to clarify the averaging period.aa. Information regarding the use of biocides should be expanded to include allchemical additives added to the cooling tower and make-upwater systems. Thebeneficial effects of these additives may impact theperformance of downstreamwastewater treatment systems (WWTS) including, but notlimited to theclarification and/or filtration of cooling tower blowdown and chemical treatmentof FGD scrubber purge water where cooling tower blowdown is used as makeupwater to the scrubber system.bb. Commenters believe that Table A-11 needs to be clarified to identify the typeof cooling systems to be included. If this is asking onlyfor condenser coolingsystems, then that needs to be stated.cc. Commenters state that in most cases, chemical additives used within coolingtower systems can often be certified by our suppliers to be free of prioritypollutants. This should be added as a fourth check-box. Q. A1-30 requests forunder the existing ELGs, regardless of whether treated prior to discharge. Assuch, EPA is characterizing these waste streams, including how much isgenerated/blown down.dd. EPA reworded the instructions to state that "Throughoutthis section,provide information for all steam electric generating units which were operatedin 2009 including units that operated for only part of 2009."With this change"idle" and "extended period of time" do not need to be defined.ee. EPA agrees. EPA deleted Q. A2-1 from the questionnaireand revised theinstructions for Q. A2-2 to include fuels used for start up.Therefore, nofurther clarification is needed.ff. EPA revised Q. A2-2 to remove the terminology “normal operation.” EPAhas also revised the question to request use of “bituminous”coal.gg. EPA deleted. Q. A2-3 and Q. A2-4 from the questionnaire.hh. EPA added questions to Section 3 asking if the plant everwashes thecatalyst on site. If so, the plant is prompted to answer similar questions thatare asked for the SCR catalyst regeneration wastewater.Additionally, EPAdefined the terms "SCR catalyst regeneration" and "SCR catalyst washing" inthe glossary of the questionnaire.ii. EPA added a "NA" box to the "Where Last SCR Catalyst RegenerationOccurred" column. EPA believes that the comment regarding "every instanceof SCR offsite regeneration" probably applies to QA3-2, inwhich case EPAagrees that it can reduce burden by limiting the response to the last tworegenerations. EPA defined the term “NOx control system” in the glossary ofthe questionnaire. EPAdoes not believe the other termsneed to be defined.jj. EPA converted Q. A3-2 to a table to allow two companies to be specified.kk. EPA has retained the request for planned systems and expects plants torespond regarding any planned systems at the time theyare completing thequestionnaire.ll. EPA revised Q. A3-9 to exclude particulate matter control systems alongwith FGD and SCR/SNCR systems that are not included in Table A-16.mm. EPA defined the term "flue gas mercury control system" in the glossaryPage 14 of 39Version: February 22, 2010CommentResponsecopies of the reports and calculation sheets, which is excessive and unnecessaryfor the development of revised ELGs and should be omittedfrom the ICR.Additionally, commenters ask does Q. A1-30 refer to monitoring in addition topriority pollutant sampling submitted with the permit renewal application orreviewed on an annual basis. Commenters ask is the fateof the cooling towerblowdown relevant to the steam electric guidelines revision. Cooling towerblowdown is used internally or the cooling tower blowdown issent to awastewater treatment system and not discharged directlyto the receiving waterbody. Are these flows still to be reported as "wastewater generated/blowndown?"dd. Commenters believe the instructions of Section 2 need to be revised. Theyare uncertain if a unit that did not operate at all in 2009 would be included. EPAneeds to define “idle” and “extended period of time.”ee. Commenters wonder what the relevance is, for purposes of effluentguidelines, of distinguishing fuels used for start-up from other fuels in Q. A2-1and recommend deleting this question. Additionally, on a natural gas-fired unit,which uses gas to both start up and generate, is there aclear demarcation forwhen start-up ends and “steady state” operation begins. Itis common practice inair permits to define “start up” and it may vary. EPA needs to clearly definewhen the start up period is over.ff. For Q. A2-2, EPA should provide a definition for “normal operation.” EPAshould also provide definitions for “Eastern Bituminous”and “WesternBituminous” as they are used in Table A-12. What is the relevance of thisquestion for effluent guidelines purposes?gg. Commenters believe that Q. A2-3 requests for data on "any oil or coal" couldyield very large amounts of data, if coal samples are collected daily. Also plantssample their coal differently, as some sample as received and other sample asfired, which could include blends of various coals. They suggest EPA to re-thinkthis request as this data is not likely readily transferable to ELG water qualitydata or standard setting. Additionally, Question A2-4 seems to imply thatanalytical data required by A2-3 is required for each mineused to supply coalburned by the unit. Question A2-3 should be revised to include onlyrepresentative data for each single type of fuel burned tominimize the ICRburden. Or EPA should consider requesting averages of available data.Additionally, EPA should consider limiting the coal analyses to volatile traceelements – mercury, selenium, chloride, and boron – and consider more detailedof the questionnaire.nn. EPA assumes the commenter is referring to Q. A3-10 andremoved therequest for "type of materials of construction" from thisquestion.oo. EPA reworded the language as suggested by the commenter.pp. EPA has revised the request to specify all technologiesstudied, but to onlyprovide reports from technologies generate wastewaters. EPA disagrees thatpilot test data requested in Q. A3-11 are not applicable to the ELG. They areuseful for evaluating potential technology options that maybe installed andgenerate future wastewater streams.qq. EPA replaced “Table A- 16’ with “Table A-17.”rr. EPA changed the date in Q. A3-13 to January 1, 2009 from January 1,2005.ss. EPA defined the term "carbon capture system" in the glossary of thequestionnaire. EPA has phrased Q. A3-14 to allow plants the flexibilitynecessary to adequately provide the information requested. EPA also revisedQ. A3-14 so that plants would only need to provide information ontechnologies that generate wastewater.tt. EPA disagrees that reports should be limited to those with wastewater“impacts” due to the ambiguity in that term, and therefore has not removed Q.A3-15 from the questionnaire.uu. EPA clarified in Q. A4-1 that processing coal includes any methods usedto prepare the coal for use at the plant including but not limited tocrushing/pulverizing coal.vv. EPA clarified in Q. A4-2 that the plant can make an estimation of the coalpile runoff, but a description of the calculation needsto be included. EPA alsoclarified the request to report number of days of dischargerather than numberof days of runoff.ww. EPA rephrased Q. A4-3 to ask "Was the coal pile runoff monitored forpH?" If yes, the plant is required to provide data.xx. EPA revised the question so that plants indicated whether the coal pilePage 15 of 39Version: February 22, 2010CommentResponsestudies at select facilities Commenters believe thatEPA's reason for requestingthe coal quality data is based on a false premise andEPA has failed to state anadequate justification for this onerous data request.hh. Commenters state that EPA should clarify Q. A3-1 toask if catalysts arewashed with water onsite, and note that this does not include regeneration withvarious acids/bases offsite. Most, if not all, catalysts are regenerated offsiteusing various acids and bases. Some plants may wash the catalyst onsite toremove fly ash. Some clarification is needed to ensureconsistent responses. Thelimited water data at most power plants will likely be of minimal benefit.Comprehensive multimedia studies (consisting of flue gas,water, and solidssampling and analyses) at numerous power plants are needed tocharacterize andbe able to accurately quantify the effects of NOx controlon water.ii. In Table A-14, EPA should define the terms “NOx control system”, “SCR”,“SNCR”, “overfire air”, and “low NOx burner”. In addition, the “Where LastSCR Catalyst Regeneration Occurred” column needs an “N/A” box. Answers tothe questions about future replacements/regenerations will be very speculativeand will depend on unit operation and current catalyst condition. Must the plantreport every instance of SCR offsite regeneration? This question needs areasonable timeframe – e.g., sent offsite within the last two years.jj. Additional lines should be provided for plants that send SCR catalyst off-siteto more than one facility for regeneration in Table A-14.kk. Q. A3-9 asks for planned Hg flue gas controls. It is unclear how power plantswould respond since a mercury rule has not been finalized. This may also dependupon other EPA actions on climate/carbon, CCPs, cooling system retrofits etc.Commenters suggest limiting "planned" to a relatively short time period, such as2 or 3 years – or a planned approach for responding to theproposed (and nowvacated) CAMR rule.ll. Commenters believe the wording in Q. A3-9 needs furtherclarification.Particulate collection systems, including baghouses, need to be excluded fromthe questionnaire, along with the FGD and SCR/SNCR systems.mm. EPA should define the term “flue gas mercury control systems.”nn. Q. A3-9 Asks for the materials of construction for all mercury controls.Commenters are unclear how this information could be used to characterizerunoff was transferred to a pond/impoundment and had the option to choosemultiple options. EPA also defined the term “discharge” in the glossary of thequestionnaire.yy. EPA revised Q. A4-5 by replacing the response option "Allleachatedischarged" with "All treated coal pile runoff discharged." InQ. A4-2, plantsshould provide their best estimate of generation.zz. “Coal washing” is defined in the glossary of the questionnaire.aaa. EPA defined blending to be the intentional mixing ofdifferent coal typesprior to combustion, and does not include natural blendingin the coal pile.bbb. EPA replaced the term "pyritic mill rejects" with "mill rejects." EPA alsodefined the term "mill rejects" in the glossary of thequestionnaire.ccc. “Waste coal” is defined in the glossary of the questionnaire. EPA alsoremoved anthracite culm and bituminous gob from examples of "Other coal."Page 16 of 39Version: February 22, 2010CommentResponsewater quality or use, especially for activated carboninjection.oo. Commenters believe that Q. A3-10 is badly designed, will result ininconsistent answers, and should be deleted. This questionrequires, inter alia,that the respondent identify “any potential effect on other water streams” causedby flue gas mercury control system processes. This language is too broad. At aminimum, it should be reworded to require identification of“any known oranticipated probable effect.”pp. Commenters had several concerns about Q. A3-11. First, they believe pilotstudies do not indicate whether the full-scale plant willactually install thistechnology and suggest limiting the request to reports thatinclude impacts onwastewater, given uncertainty over the dates and compliance approaches offuture rulemaking. In addition, data from a pilot testthat will not be used at theplant would also not appear to be relevant to this ICR andonly increases theburden on each respondent. Pilot studies are usually only ofa slip-stream of fluegas and are of short duration. In addition, many companieshave performedmultiple pilot-scale flue gas mercury control studies. Many of these experimentaltests have never been implemented full scale; therefore, the results are notpertinent to the effluent guidelines rulemaking. Additionally, most of thesestudies have not evaluated wastewater impacts. At a minimum, this questionshould be limited to reports that include wastewater impacts. This request isextremely burdensome and will require a significant amount oftime to locatereports.qq. In the description of Table A- 17, there is a reference to Table A- 16 that iswrong – it should be A-17.rr. In Q. A3-13 the time period for data request is for2005 instead of 2009.Commenters ask if this question should read as the previous section as January 1,2009 or is it 2005.ss. EPA should define what it means by a "carbon capture system" and providethat definition to the public for review and comment prior to finalizing thequestionnaire. In addition, the request for "any potential effect on other waterstreams" in Question Q. A-14 is too vague and speculative. EPA should identifythe effects that it is concerned about and specifically identify them in thequestion so the respondents can determine if they are applicable. Commenters arealso concerned that the open ended nature of this question will result ininconsistent answers.Page 17 of 39Version: February 22, 2010CommentResponsett. Some companies have performed multiple pilot-scale carbon capture studies.Many of these experimental tests have never been implemented full-scale;therefore, the results are not pertinent to the effluent guidelines rulemaking.Additionally, most of these studies have not evaluated wastewater impacts. At aminimum, Q. A3-15 should be limited to reports that includewastewaterimpacts. This request is extremely burdensome and will require a significantamount of time to locate reports.uu. EPA needs to define “process.” Does crushing/pulverizing coal constituteprocessing coal?vv. Q. Commenters believe that A4-2 is badly phrased andshould be modified ordeleted. EPA should allow the use of an estimate in Q. A4-2 because actualamounts will vary. Companies can report on rainfall received or the amount ofdischarge, but cannot report the total runoff or how manydays it took to collectthe runoff. This is because runoff is affected by manyfactors, includingreuse/recycling, evaporation rate, ambient temperature, wind speed relativehumidity, and cloud cover, as well as the frequency, amount,and duration ofprecipitation.ww. Coal pile runoff is not required to be monitored forpH. Q. A4-3 shouldinclude a response box for “Not Monitored.”xx. In Q. A4-4 the respondent must specify if coal pile runoff is segregated,commingled, or discharged without treatment. Commenters wonder how therespondent answers if the plant has the ability to do any of these options,depending on operating needs? Also, EPA should define “discharged.”yy. Q. A4-2 through Q. A4-5 refer to coal pile runoff. One commenter states thatthe volume of coal pile runoff at some of our sites isimmediately captured andreused in ash sluicing systems. There is no direct measurement of runoff volumescollected during the process; it would strictly have tobe a calculation of inchesof precipitation multiplied by the surface area of coal yard. Calling coal pilerunoff leachate, whether treated and discharged or otherwise reused, is incorrect.It is not leachate, it is surface runoff. Therefore, the word “effluent” or thephrase “treated coal pile runoff” should be substituted for “leachate” in the thirdchoice for this question.zz. EPA should define “coal washing.”Page 18 of 39Version: February 22, 2010CommentResponseaaa. Commenters believe that Q. A4-10 should be clarified so that it focuses onlyon blending various coal types, such as PRB with eastern bituminous (i.e., theintentional mixing of separate piles prior to combustion.. Coals from varioussuppliers are blended naturally when each coal shipmentis placed on the pile.bbb. EPA should define the terms “pyritic mill rejects”and “mill rejects.”ccc. EPA should define the term “waste coal” and distinguish it from anthraciteculm and bituminous gob. Typically, culm and gob are considered waste coal.Part B/Flue Gas Desulfurization (FGD) Systemsa. Commenters noted that the use of “FGD System ID” inTable B-1 does notagree with the nomenclature of “Sulfur Dioxide Control Systems” used in TableA-17. Commenters also noted that some of the information requested in TableB-1 is already reported in Form EIA-860 and Form EIA-923.b. Commenters believe that EPA should identify a timeperiod for “planned”FGD systems and that it should be limited to relativelyshort time period, such as2 to 3 years.c. Commenters believe that the terms “purge stream” and “scrubber purge”should be defined.d. Commenters noted that Q. B1-4 does not include a responsecategory foradipic acid.e. Commenters noted that Table B-4 requested the materials of construction forthe FGD systems, including all of the pumps; but the shafts, impellers, housing,etc., on the pumps may have different materials of construction.f. Commenters noted that if a respondent answers “No” toQ. B2-1, therespondent is allowed to skip to Section 3; however, Section 3 is also associatedwith Wet FGD systems. Commenters recommended that ifa respondent answers“No” to Q. B2-1, the respondent can skip to Section 4.g. Commenters noted that the phrase "which section of system," in Q. B2-3 couldpotentially lead to a wide range of responses; therefore, the commenterssuggested re-phrasing sentence to "and indicate whichspecific equipment unitsofthe FGD system determines...."a. EPA deleted Table A-17 from the questionnaire; therefore, EPA did notmake any revisions to Table B-1. Additionally, EPA acknowledges that someof the information in Table B-1 is reported in Form EIA-860 and Form EIA923; however, EPA is using 2009 as its base year for the technology evaluationfor this rulemaking and 2009 EIA will likely not be publicly available until themiddle of 2011. Additionally, EPA is requesting information for FGD systemsplanned until 2020, which would not be available from either EIA form.b. EPA revised Q. B1-3 by directing plants to provide information for“planned” FGD systems that will be operating or beginconstruction/installation by Dec 31, 2020.c. EPA replaced the term "purge stream" and "scrubber purge" with "FGDscrubber purge (or slurry discharge)" throughout Part B of thequestionnaire.EPA also defined the term “FGD scrubber purge” and “slurry discharge” in theglossary of the questionnaire.d. EPA added adipic acid as an option in Table B-3.e. EPA deleted Table B-4; however, EPA is now requestingthe materials forthe equipment unit(s) that determine the maximum design chloridesconcentration of the FGD system. If multiple materials of construction areused in the equipment unit(s), the plants are ask to provide the material ofconstruction that is most vulnerable to corrosion due tochlorides.f. EPA corrected the skip pattern for this question.g. EPA incorporated these changes.Page 19 of 39Version: February 22, 2010CommentResponseh. Commenters noted that Q. B2-4 asks for system parameters “used to controlthe FGD slurry blowdown from the FGD system.” The commenters askedwhether this refers to the parameters used to controlthe quality of the FGD slurryas it leaves the absorber vessel, or at some otherpoint in the process.i. Commenters noted that Q. B2-5 asks for the water sources that may be used asa source of FGD slurry water or FGD slurry water makeup. The commentersstated that the second reference to slurry water shouldbe deleted.j. Commenters stated that many companies do not measure the mist eliminatorwash, limestone preparation water, and FGD make-up waterflow rates and thatthe flows vary widely based on operating conditions. Commenters believe thatthese questions are unlikely to generate usable, consistent responses.Commenters believe that an estimate would better fit anannual average insteadof the stated instantaneous flows, durations, and frequency. A water balancebased on annual flows and power production would be a more accurate reflectionof operation.k. Commenters noted that Table X-X, which is referenced in several questions,was not provided.l. Commenters noted that Q. B2-13 seems to presume thatblending fly ash withFGD solids always results in a pozzolanic material and that is not always thecase.m. Commenters noted that Q. B2-14 uses the term “blowdown slurry,” and askedif that is the same as “slurry blowdown”?n. Commenters requested that EPA clarify the distinctionbetween solidsseparation and solids settling.o. Commenters requested that EPA define the term “gypsum stack” from Q. B2-15.p. Commenters noted that Q. B2-16 uses the terms “permanently” and“temporarily” regarding the storage of FGD solids in landfills and/orpond/impoundments. The commenters requested that EPA define these terms.q. Commenters believe that the 5 year period of time requested for Tables B-5,B-6, B-8, and B-9 is not necessary to gain an understandingof FGD solidsh. EPA revised Q. B2-4 to read “Indicate the FGD systemparameter(s) that areused to determine when the FGD slurry is blown down fromthe FGD system.”i. EPA reworded Q. B2-5 to ask for “water sources that maybe used as asource of FGD reagent preparation water or absorber make-up water (e.g.,fresh intake, recycled process water).”j. EPA changed the wording of those questions to ask for“typical flow rate,duration, and frequency” and, if the FGD was not operating in 2009, the flowrate data for 2010 should be provided.k. EPA included the process codes in the dropdown boxes in the 2ndFRNversion of the questionnaire. EPA also added a “Code Tables” tab at the endof each part for reference.l. EPA revised the question to ask if the FGD solids aremixed with ash andthen included an additional question to ask whether a pozzolanic material isformed.m. EPA incorporated these changes by replacing "blowdown slurry" with"FGD slurry blowdown" throughout this part.n. EPA amended Figure B-1 to clarify “FGD solids separation” systems forPart B. EPA also added the term “FGD solids separation” to the glossary.o. EPA replaced the term “gypsum stack” with “gypsum stacking.”Additionally, EPA defined the term “gypsum stacking” in the glossary of thequestionnaire.p. EPA provided an example in the question to clarify both temporary andpermanent storage.q. EPA revised the question to request three years of datato minimize burden.However, EPA believes obtaining data that spans 2005-2009 will betterrepresent disposal and sale practices for FGD solids, so has instead requesteddata for 2005, 2007, and 2009. EPA acknowledges that some of theinformation regarding FGD solids disposition is included inForm EIA-923;however, the 2009 data will not be available until the middle of 2011.Additionally, the information is reported on a plant level to EIA, whereas,EPA is requesting the information on a unit level todetermine how differentPage 20 of 39Version: February 22, 2010CommentResponsedisposal and resale. Commenters believe the request is overly burdensome and isunlikely to provide information that is more representative than the 2007 through2009 time period. The commenters recommended using a 3 yearperiod of timeto minimize the questionnaire burden. Commenters also noted that the some ofthe information regarding FGD solids disposition is reported in Form EIA-923.r. Commenters noted that Q. B2-17 through B2-19 request information regardingrevenue generated from marketing of FGD solids. Commenters believe that thepotential changes to the classification of ash products under RCRA couldseverely restrict or eliminate any beneficial reuse ofcoal combustion residualsand therefore, would decrease or eliminate the projectedrevenue streams andneeds to be considered when EPA begins analysis for the compliance cost model.s. Commenters suggested that Q. B2-18 and B2-19 should be redesigned to bemore explicit about the costs that should be included, suchas labor costs.Additionally, commenters noted that Q. B2- 18 requests totalcosts incurred toremove or dispose of FGD solids in calendar year 2009, whileTable B-6 asks forfive years of FGD solids sales and marketing information. The commentersbelieve this creates an incomplete economic picture of the costs and benefits ofFGD solids management.t. Commenters asked what basis the concentration of chlorides in FGD solids isto be provided (e.g., dry solids, liquor, other).u. Commenters believe that the terminology used in Table B-7 is confusing.Commenters suggest that the terms be defined and used consistently throughoutthe ICR. Commenters also noted that an estimate would better fit an annualaverage instead of the stated instantaneous flows, durations, and frequency.Additionally, commenters asked what period of time the average should apply(e.g., calendar year 2009), as well as whether the average should be a median,mode, or mean value.v. Commenters noted that it is difficult to obtain representative analytical data onuntreated FGD purge stream, as requested in Q. B3-3, due to itshigh TSS andheterogeneous nature. Commenters suggested that EPA should requestinformation on sample collection and analysis techniques. Commenters alsobelieve that the data request should be limited to datacollected during 2009because providing 2010 data will be too burdensome, in that thedata needs to bevalidated and analyzed before it is provided. Commenters requested that EPAdefine “solids separation process” and provide examples, such as, how does aunit/FGD system characteristics impact the dispositionof the FGD solids.r. EPA acknowledges that future rules may affect the use of FGD solids;however, past actions will assist EPA in characterizing options. EPA limitedthe request to three years to minimize burden.s. EPA provided additional clarification in Q. B2-18 on whatshould beincluded in the costs (e.g., labor, materials, transportation, energy). Inaddition, EPA combined Q. B2-18 with Q. B2-19 requesting the costs for2005, 2007, and 2009. In the table, EPA included separate rows foreach ofthe items identified in QB2-19 and requested the estimated costs for each itemand the sum at the bottom of the table.t. EPA clarified that the plants should provide the chlorides concentration on awet basis (i.e., analyze the chlorides for the FGD solids with the moisturecontent included); however, if they do not have the concentration on a wetbasis they should provide the dry-basis concentrationand note it in thecomments.u. EPA discussed potential changes to the terminology with UWAG andrevised it in Figure B-1 and throughout Part B. In Table B-7, EPA removedthe term “slurry water.” EPA replaced the “Slurry Blowdown Returned toAbsorber as Makeup following Solids Separation” column heading with “SolidSeparation Recycle Returned to Absorber” and replaced the term “average”with “typical” in the column headers. EPA also defined the term “FGDreagent preparation water” in the glossary of the questionnaire.v. EPA clarified in Q. B3-3 that respondents can provide additionalinformation regarding the sample collection techniques or analytical methodsin the “Part B Comments” tab at the end of the part. EPA defined the term"FGD solids separation" in the glossary and added clarification that themonitoring data should be collected after the last solidseparation process, ifmultiple processes exist, and that the “last 12 months”applies to the date ofthe receipt of the ICR. In addition, EPA clarified thetype of monitoringlocation by providing examples. EPA notes that they arerequesting fordilution corrected quantitation limits because it is asking for the samplespecific quantitation limit. EPA disagrees that data request should only belimited to data collected under normal operating conditions, because the plantscan provide additional details regarding any data provided inthe “Part BComments” tab at the end of the part.Page 21 of 39Version: February 22, 2010CommentResponseplant with primary and secondary hydroclones respond. Commenters also believethat EPA should provide clear instructions for describing the monitoring location.Commenters noted that EPA asks for the sample-specific nominal quantitationlimit stipulated for the method used; however, they believe EPA should berequesting the sample-specific (dilution corrected) quantitation limit.Additionally, commenters believe these terms also need to be defined.Commenters believe that the data request should be limited to data collectedunder normal operating conditions and that any data collected during researchand development activities should be excluded.w. Commenters believe that the requested information in Q.B3-3 is important,however, they believe that providing the monitoring data in the specific ICRelectronic format adds additional burden to respondents. Commenters noted thatmonitoring data, in most cases, were not provided in electronic format and werenot supplied in the ICR specified format. Therefore, hardcopies of the monitoringdata could be scanned and provided, but commenter believe the manual transferof this data into electronic format is not feasible inthe time period provided.x. Commenters believe that the submittal of monitoring data requested in Q. B3-3 should be limited to that obtained using EPA-approved laboratories andmethods. Commenters also believe it should be limited toNPDES permitrequired monitoring.y. Commenters noted that FGD water streams can be sentto a pond with aNPDES permitted outfall, but not discharge the water since the FGD wastestream has been sent to the pond. Therefore, the FGDpond water is stored inpreparation for possible discharge, and the answer to Q. B3-4 is neither yes norno, the only two options available. A third option, suchas a general “Other(Explain)” is needed for this question.z. Commenters requested that EPA distinguish “FGD water”from “FGD purgewastewater.”aa. Commenters requested that EPA define “mill reject sluice.”bb. Commenters noted that Q. B3-8 is not appropriately drafted for facilities thatuse deep well injection as the ultimate destination for their FGD water stream.Commenters suggested that EPA add an “other – please specify”category ofresponse to this question.w. EPA understands that the transfer of data to an electronic format can addburden if not already available electronically. However,EPA believes this isnecessary to ensure collection of all data requested in a format that is notsubject to misinterpretation by EPA.x. EPA disagrees with the suggestion to limit responsesto data collected forNPDES monitoring because plants are not typically required to collectuntreated FGD scrubber purge samples as part of NPDES permitting, but areknown to collect these data internally for evaluationof their operation.Additionally, all monitoring data collected should be provided regardless ofmethod or laboratory as it is still useful for characterizing the FGD scrubberpurge stream.y. EPA has changed the wording of Q. B3-4 to ask if the plant transfers “theFGD scrubber purge (or slurry discharge) to a settling pond."z. EPA replaced the term “FGD water” to “FGD scrubberpurge (or slurrydischarge).”aa. EPA defined the term “mill reject sluice” in the glossary of thequestionnairebb. EPA added a specific option for “deep well injection”and another optionfor “Other.”cc. EPA did not incorporate these changes because information regarding thespecific chemicals used in the system is obtained in Part D of the ICR.dd. EPA replaced the term "gypsum stack runoff" with "gypsumpile runoff."EPA defined the terms “gypsum wash water” and “gypsum pile runoff” in theglossary for the questionnaire.ee. EPA is gathering data on all potential technology options that can reduce oreliminate potential pollutant discharges associated with this industry.Therefore, information on dry solids handling is pertinent to the revision of theELG.ff. EPA acknowledges that future rules may affect theuse of FGD solids;however, past actions will assist EPA in characterizing options. EPA limitedPage 22 of 39Version: February 22, 2010CommentResponsecc. Commenters noted that Q. B3-7 chemical precipitation option does not breakout lime, iron, and sulfide. Commenters suggest that EPA provide extra responsecategories for lime, iron, and sulfide.dd. Commenters suggested that EPA define “gypsum wash water” and “gypsumstack runoff.”ee. There are several instances where the questionnairerequests detailedinformation on processes that cannot reasonably be expected to contributewastewater sources that would be covered by the ELG's (forexample QuestionB4-11 regarding five years of disposal records for dry FGD solids.ff. Commenters noted that information on revenue generated from marketing ofdry FGD ash in Q. B4-12 could be significantly impacted by changes to ashdisposal regulations. Commenters also noted that the technologies that may berequired to meet upcoming mercury removal requirements could negativelyimpact the marketability of the ash products. For example, use of activatedcarbon for mercury removal can significantly change thecharacteristics of theash produced and make it undesirable for other uses. Commenters believe thiswould significantly impact the accuracy of the compliancecost model.gg. Commenters suggested that EPA clarify what should be included andexcluded when calculating total costs in Q. B4-13.hh. Commenters suggested that changes be made to Table B-10 regardingchemical additives, types of FGD system, and materialsof construction.ii. Commenters noted that Q. B1-1 asks information that isrequested in FormEIA-860.the request to three years to minimize burden.gg. EPA provided additional clarification in this question to include costs forlabor, materials, transportation, and energy.hh. EPA deleted Table B-10 from Part B; however, EPA made the followingchanges to the appropriate drop down boxes and/or the “CodeTables” tab atthe end of Part B:-EPA added “Soda ash” to the list of sorbent types;-EPA changed “TMT-15” to “Organosulfide”;-EPA added an option for “spray/tray”; and-EPA added the list of FGD materials of construction to to options in Q.B4-3 (based on 2ndFRN version numbering).EPA disagrees that the standard types of FGD systems need to be specificallydefined; therefore, EPA did not define mechanically aided.ii. EPA acknowledges that the information collected inQ. B1-1 is alsocollected in Form EIA-860; however, EPA is using the information to identifyif the plant has to complete the remainder of Part B. Additionally, Q. B1-1asks requests information for planned FGD systems that go beyond thatcaptured by Form EIA-860.Part C/Ash Handlinga. The conversion to dry handling could greatly increasethe costs for dustsuppression activities on the site yet there is no mention of this in the survey.b. Commenters believe that the 5 year period of timefor requested for Part C isnot necessary to gain an understanding of fly ash and bottom ash solids disposaland resale and recommends using a 3 year period of time to minimize the ICRburden.c. Commenters believe that Part C is not well laid outfor a facility that handlesboth bottom ash and fly ash dry, but combines all the ash in a silo for storagea. EPA has revised the cost sections in Part C, whichinclude obtaining costsfor dust suppression activities (e.g., around silos in whichfly ash conditioningoccurs, and that associated with landfilling, etc.).b. EPA revised the instructions to request information from three years (2005,2007, and 2009) instead of 2005-2009.c. To address the possibility of plants that combine fly ash and bottom ash in asilo, EPA has added a new section to Part C for combined fly ash and bottomPage 23 of 39Version: February 22, 2010CommentResponseprior to beneficial reuse and that EPA should consider, for each portion of Part C,how such a facility would respond to the question.d. Commenters suggested that Table C-1 be modified in several ways includingadding the definition of “average” amount of dry fly ash, andspecifying thatinformation is for the year 2009. Commenters also believe that loss on ignition isnot relevant to the effluent guidelines rulemaking and that determining thepercent of fly ash handled as dry or wet will be difficult to determine for a plantthat operates both systems. Also commenters requested the clarification of theton basis in Tables C-1, C-6, C-13, and C-14 to indicatedry tons of ash.e. Commenters noted that Q. C1-4 and C1-5 do not take into account anychanges or retrofits from one type of dry ash handling system to another type ofdry ash handling system and ask how the reasons for flyash and bottom ashhandling system retrofits are relevant to the rulemaking.f. Commenters believe that Q. C1-5, C1-6, C1-24, C1-27 and 2-5 are very openended and will produce inconsistent answers. Commentersstated that there aremany types of changes that could be discussed under this question, includingphysical changes to the facility, changes in personnel, changes in training,changes in ash disposal practices, changes in ash marketing practices. Inaddition, commenters noted that current personnel may not beaware of whycertain actions/retrofits occurred, and there may not be any documentationavailable to answer this question.g. Commenters noted that Table C-2 in Q. C1-9 asks for percent moisture of flyash, but does not segregate the question for ash wastes thatare moistureconditioned prior to final disposal. Commenters also believe that the tons of flyash transported to a silo at a plant that also sluices fly ash will be difficult todetermine, since this value is not calculated/measured/recorded.h. Commenters indicated that Q. C1-11, Q. C1-13, Q. C3-3, andQ.C4-3 refer toprocess wastewater/treatment codes in Table X-X, whichis not present in thedraft questionnaire.i. Commenters believe that potential changes in revenue streams from beneficialuses as a result of changes to ash handling and air emissions regulations must beaccounted for in the compliance cost model and that morerestrictive stateregulations on beneficial use of ash products need to be considered indevelopment of a national compliance cost model.ash handling.d. EPA replaced the term “average” with “typical” amount of fly ash producedand specified where data should be provided for the year 2009. EPA kept theloss on ignition of fly ash in Table C-1 to determine potential markets for flyash for EPA’s cost analysis. EPA recognizes that providing the wet and dryash handling percentage information may be more difficult for plants that donot keep track of this information. Therefore, they should provide their bestestimates, which is explained in the front matter of thequestionnaire. Also,EPA revised the tables and other questions throughout thepart to requiretonnage on a dry basis where appropriate.e. EPA would use the information to assess/predict the number of plants thatmay convert to dry ash handling, apart from a potential EPA requirementAdditionally, EPA would use this question to assess the reasons behindconverting to dry ash handling and how this might affectfuture operations.This information will be considered when evaluating the technical feasibilityof such options. EPA modified these questions and added additional questionsto account for dry fly ash handling systems that were modified/retrofitted.EPA made the same changes to the bottom ash section.f. EPA added response options to the questions to obtainconsistent responses.Additionally, the questions were expanded to encompass the entire dry ashhandling system, including components associated with transport/disposal.EPA recognizes that providing this information may bemore difficult forplants that do not keep track of this information. Therefore, EPA expectsplants to provide information to the best of their ability and note anyuncertainties in the Comments page.g. EPA revised Table C-2 by changing the column heading to “PercentMoisture of the Fly Ash Entering Destination.”EPA recognizes that providingthis information may be more difficult for plants that donot keep track of thisinformation. Therefore, they should provide their bestestimates, which isexplained in the front matter of the questionnaire.h. EPA included the process codes in the dropdown boxes in the 2ndFRNversion of the questionnaire. EPA also added a “Code Tables” tab at the endof each part to refer to.i. EPA is aware that such changes may affect beneficialuses, and EPA will bePage 24 of 39Version: February 22, 2010CommentResponsej. Q. C1-13 and Q. C1-14 relate to water usage in fly ashwhich is sold in order toevaluate water reuse opportunities. Commenters noted that water may also beused with fly ash that is not sold, and is a potentialreuse option. Commentersalso asked why data on chlorides or solids in the waterused for moistening flyash is being requested and recommend that EPA ask specifically aboutoperational criteria – i.e., “Identify any other operational criteria that the sourcewater must meet.”k. Commenters believe that Q. C1-16 and Q. C2-28 are likelyto produceinconsistent answers because EPA does not specify whatshould be included in“total costs” and asked whether costs associated with constructing a landfill anddry handling systems, adjustments to the facility air permit or labor costs shouldbe included.l. Commenters noted that there is no information available for fly ash quantitiesrelated to individual electrostatic precipitators..Also, commenters suggested thatthe instructions for Q. C1-18 refer to “dry to wet” instead of “wet to dryjunctions” and clarify how the distance from the dry-to-wet junctions and the ashponds or other final destination should be measured particularly if multiple pondswere used. Commenters noted that in Table C-5 Column 3’s heading should be“Number of Dry-to-Wet Mixing Junctions” and needs thephrase “ junctions”added in the second row.m. Commenters believe that Q. C1-21 is very open-ended and will produceinconsistent responses.n. Commenters believe that systems that are “planned”should be limited tosystems that are planned to be installed by the end of 2012.o. Commenters believe that in Q. C1-26 and Table C-6 the term “Wet Fly Ash” ispotentially misleading and recommend changing the wordingfrom “Wet FlyAsh” to “Fly Ash Moved by Wet Handling” and that a similarchange should bemade in the bottom ash section.p. Commenters believe that the requirement to include bid proposals in Q. C1-27is unnecessary because bid proposals may have little relation to actual costestimates for an entire project and can reflect manypricing issues that are notobjective, such as the business relationship between thesite and the bidder.Commenters also believe that bids do not reflect true costs of theassessing the impact.j. EPA revised the skip patterns to require all plants that complete the dry flyash handling section to complete Q. C1-13 and Q. C1-14, notjust those thatmarket the ash. EPA is requesting information chloridesand solids in thewater used for moistening fly ash in order to evaluate water reuseopportunities. If the plantdoes not measure chlorides/solids percentage, theycan respond in the "Other" space provided.EPA did not modify the question to ask only about operationalcriteria.k. EPA deleted Q. C1-16 and C2-28 and revised the cost sections of Part C toinclude separate sections for fly ash conveyance, intermediate storage, andtransport/disposal.l. EPA deleted the request for “Number of Hopper Trains inESP/Baghouse” inquestion C1-18 and EPA replaced any references in Q. C1-18 of“wet to dry”with “dry to wet.” Additionally, EPA specified in the instructions of thequestion that the distance to the ash pond(s) is the distance to the end of thesluice pipe at the furthest ash pond (if multiple ponds). EPAadded the phrase“junctions” to the second row of column 3 in Table C-5.m. EPA phrased Q. C1-21 in this manner to provide plants the flexibilitynecessary to provide the information requested.n. EPA revised questions throughout the questionnaire by directing plants toprovide information on “planned” units/systems that willbe operating or beginconstruction/installation by Dec 31, 2020. Power plants have made substantialchanges to equipment in recent years and are expected to continue makingsignificant changes in the near future. EPA is collecting this information toallow the Agency to reasonably predict the costs and other impacts associatedwith revisions to the ELGs.o. EPA revised Q. C1-26 and Table C-6 by replacing the term “Wet Fly Ash”with “Fly Ash Transported by Wet Sluicing” and made the same change in thebottom ash section.p. EPA recognizes the limitations of system/cost information in bidproposals/engineering reports; however they may provide useful informationto fill data gaps, particularly for previously planned wastewater treatmentsystems, and as general verification of other ash handling system costsobtained. Additionally, EPA provided clarification to mark any bidPage 25 of 39Version: February 22, 2010CommentResponseinstallation/construction and that EPA should not requestthe submittal of bidinformation for any purpose.q. Commenters believe that the O&M and capital cost categories are too specificin Tables C-7 and C-8. Commenters recommended specifying thetypes of O&Mand indirect and direct capital costs to be considered in the description forclarification and requesting only the total O&M cost and total capital costs inorder to reduce the burden of the ICR. Also, commenters stated that O&M costsare not tracked by individual systems, such as the fly ash handling system butinstead, generally compiled for all CCB systems (bottom ash, fly ash, scrubbersolids, etc.) together and therefore, commenters believe that industry accountingsystems make this table (and all the similar tables)very difficult and timeconsuming to prepare.r. Commenters noted that Q. C1-27 and Q. C2-27 request capital costs, but do notrequest information related to design ash generation rates (only actual 2009 rates)and recommended adding a question to request the design ash handlingrate, sothat capital costs can be adjusted if actual generation rates differ from design.s. Commenters believe that asking how fly ash handlingsystem components areused between multiple generating units is open-ended and likely to produceinconsistent answers and that EPA should specify what it means by “O&M orcapital cost overlap.”t. Commenters noted that there should be some information in the instructions inSection 2 telling respondents which question to skip to if there are no dry bottomash collection systems and requested the addition of a question asking if the planthas a dry bottom ash handling system.u. Commenters stated that bottom ash produced is not a measured value but isinstead calculated based on plant and coal characteristics and that EPA shouldremove the “check” in the box for “both” in column 3, row 2.v. Commenters believe that Q. C1-3 and Q. C2-2 are veryopen-ended and willlikely produce inconsistent answers.w. Commenters asked how the distance should be calculated when multipleparties or locations received bottom ash in 2009.x. Commenters stated that EPA needs to define “solid wastes” for purposes ofproposals/engineering reports CBI, if applicable.q. The O&M and capital cost breakouts will allow EPA tomost accuratelycompare costs for ash handling systems in the industry. EPAexpects plants toprovide information to the best of their ability, providing estimates ifnecessary. Estimated responses should be noted in theComments page.Also, Obtaining separate O&M costs for fly ash and bottom ash handlingsystems (and separate from other CCB systems) will becritical for EPA's costanalysis. EPA expects plants to provide these data to the best of their ability,using estimates as necessary.r. EPA added questions requesting the design ash handling rate in the bottomand fly ash handling system sections.s. EPA changed the questionnaire sections to request dataon ash handlingsystemsrather than on the electric generating unit level, which shouldminimize instances of reporting “overlap.” Overlap occurs when more thanone system shares common components (e.g., intermediatestorage silo). Inaddition, EPA requested systems to be defined for conveyanceversus storageversus transport and disposal, and added more description of how to bestdefine systems to avoid this reporting “overlap.”t. EPA modified the subsection instructions to indicatethat the subsectionshould only be filled out for dry bottom ash handling systems.u. EPA expects plants to provide accurate data to the bestof their ability,providing estimated data as necessary. EPA revised Table C-9 so the latter partof the comment is no longer relevant.v. EPA expanded these questions into multiple questions tofind out morespecifically why the fly/bottom ash is sluiced and whether the plant has thecapability to handle all fly/bottom ash dry.w. EPA revised Table C-10 to provide long drop-down menus that providemultiple options for each of the types of destinations currently listed (for eachrow in the table).x. EPA replaced the term “solid waste” with “bottom ash disposal;” therefore,the term “solid waste” is not defined in the glossary ofthe questionnaire.Page 26 of 39Version: February 22, 2010CommentResponsethis Table C-13.y. Commenters believe that Q. C2-20 through Q. C2-27 should clarify if theAgency is referring to wet handling, wet disposal, or both. Subsequent questionsshould be structured to address the desired scenarios.z. Commenters suggested that the cost of any modifications required to installdry bottom ash handling systems be requested as part of Q. C2-22.aa. Commenters stated that segregation of the ash types requested in sections 3and 4 varies from plant to plant and on a unit by unit basis and believe that it maynot be possible to provide all of the information, suchas that requested inquestion C3-2.bb. Commenters stated that one option EPA is consideringis to establish federalnon-hazardous waste regulations for CCBs pursuant to RCRA Subtitle D and thatsuch a regulation would impose requirements for the landfilling of coal ash andother CCBs, such as possible requirements for landfill liners, leachate collectionsystems, and possible phase-out and closure of CCB surface impoundments.Commenters believe that if EPA finalized the rule usingthis option, significantportions of the Questionnaire would be rendered largely obsolete or irrelevantincluding the much of Part C. Commenters also believe that if EPA proceedswith the Subtitle C option, even more of Part C would become irrelevant forpurposes of the effluent guidelines rulemaking.cc. Commenters stated that the typical technologies fordry bottom ashconversions rely upon a long, water-filled rectangular trough at the base of aboiler, with a drag out chain and dry conveyor to remove the ash from the boilerbuilding and while the space can usually be allocated for a new facility or unit,most existing boilers have no room for this equipment. Commenters indicatedthat the bases of many existing boilers are located insmall sub-basements thatare surrounded by massive amounts of steel and concrete that support the multistory boilers and to re-engineer the base of these boilers to provide room for atrough, drag-out chain and conveyor would require removing and relocatingmassive amounts of steel and concrete supports which is amajor impediment todry bottom ash retrofits at most existing facilities. Commenters noted that thequestionnaire does not ask any questions about the feasibility of retrofittingbottom ash handling at such facilities and recommended thatat a minimum, EPAshould develop a set of questions about the following: (1) whether there isy. EPA defined the terms “wet bottom ash handling” and“dry bottom ashhandling” in the Part C instructions, clarified that Q.C2-24 refers to bottomash that is moved by wet sluicing.z. EPA requested the costs of modifications required to install bottom ashhandling systems in the bottom ash handling system cost sections.aa. EPA did not revise the question, because EPA expects plants to providedata to the best of their ability, providing estimates if necessary. However,EPA did add a question asking whether economizer and air heater ash arehandled together. If this is the case, the plant can answer the economizer ashsection for economizer and air heater ash together.bb. EPA is not removing any questions in Part C, becauseEPA believes theinformation requested in this part is independently important regardless of theoutcome of the CCB rule.cc. EPA added questions requesting the estimated length of the outagenecessary to perform a bottom ash retrofit and asking whatmodifications arenecessary for a dry bottom ash retrofit. However, instead of including aquestion requesting the space available below or around boiler, EPA hasrequested engineering diagrams to depict the configuration and location of theash handling conveyance system.Page 27 of 39Version: February 22, 2010CommentResponseavailable space for a possible bottom ash retrofit; (2)whether the boiler’s base isbelow grade; (3) the estimated length of the outage necessary to perform abottom ash retrofit; and (4) a description of the equipment necessary to beinstalled for a dry bottom ash retrofit.Part D/Pond/Impoundment Systems and Other Wastewater TreatmentOperationsa. Commenters expressed their concern regarding the instructions and terms usedin Part D. For example, respondents were confused on whether or notponds/impoundments that perform treatment should be includedasponds/impoundments or wastewater treatment units. Commenters also expressedconcerns about missing definitions for key terms throughout part D. These termsinclude things such as non-pond unit, “planned activity”, andpond/impoundmentunit versus system. EPA should confirm that the responsesto Part D are limitedto CCB management units.b. Throughout Part D, questions regarding retired units should not be included ifthe pond/impoundment unit discharges wastewaters other than stormwater (e.g.,leachate).c. Under the section on closed pond/impoundment units there is no mention ofpond dewatering systems and the costs associated with installation and operationof those systems. These costs should be included in any compliance cost model.d. In Q. D1-1 and Table D-1, EPA does not define what itmeans by “retired” or“closed” pond/impoundment systems. These terms should be defined.e. Commenters suggested revising the last column headingof Table D-1 to read"Individual Ponds/Impoundments Included in the Pond/Impoundment System(identified in Table A-4)."f. It is unclear how to label ponds in Q. D1-1 and Q. D1-2. Clarify how pondsshould be labeled.g and h. Q. D1-3 and Q. D1-5 are overly burdensome and will provideinconsistent answers. The reliability of study data varies, particularly as studiesbecome dated and information about correct sampling andanalysis techniques isdeveloped. It is important to ensure that older, outdated studies are not relied onfor purposes of this rulemaking. In addition, the ICR should inquire aboutconcerns associated with the quality of the study data. EPA should requestinformation only on full-scale studies conducted from January 2005 or 2007 toa. EPA has carefully reviewed and revised the instructions in Part D to clarifythe type information that is being requested. For example,it is clear thatponds/impoundments that perform treatment should be identified as apond/impoundment system, unless part of a broader wastewater treatmentsystem. Clear definitions and examples were added to thePart D instructionsand to the glossary to aid respondents in answering thequestionnaire. EPAalso provided guidance for requests of “planned activity” asa result of publiccomment.b. EPA kept all questions regarding retired units, because they are used togather information on trends in the life of pond systems, to gain knowledge onBMPs for closed or retired units, and to understand costs required toimplement or close a pond/impoundment.c. EPA believes that Q. D3-21, which asks facilities todescribe the closureprocess for ponds/impoundments (including required steps andassociatedcosts), captures any dewatering process associated withthe closing ofponds/impoundments. EPA clarified that the respondent mustinclude thecosts associated with the closure.d. EPA has set up Part D to allow all ponds to be reported as either“active/inactive/operating,” “retired/closed,” or “planned” and does not believeit is necessary to define these terms individually. Plants should classify pondsin the most appropriate category.e. EPA incorporated these changes.f. EPA revised the example in the instructions to provide additionalclarification on how to label the pond designations. EPA has also provided toexample diagrams (EPA_D-1 and D-2) to Part D for furtherclarification.g and h. EPA revised these questions to request studies since2000 (versus1995) to reduce burden. EPA also removed the detailed request for bench-scalePage 28 of 39Version: February 22, 2010CommentResponseDecember 2009..i. Does Section 2 include all wastewater ponds including non-ash or industrialwastewater-only ponds?j. Commenters stated that because specific instructionsare provided and must bemet for the Block Diagram requested in Q. D2-1, existing block diagrams willnot meet these requirements, and block diagrams from planned WWTS will needto be more fully developed. In addition, diagrams are typically prepared by ourenvironmental consultants when preparing permit applications. Therefore, nonewill contain data from 2009. As a result, subcontractors will be required tocomplete this activity. Also, final destinations required in the diagram should begeneral and average flow rates should be estimates in orderto match Table D-3.k. Many of the flows requested are not currently monitored. Normally, thedischarge flow is taken from reading pump curves on the intake. It is unlikelythat the resulting “water balance” will actually balance because of the number ofestimations involved.l. EPA needs to provide Table X-X.m. Table D-3 requests information on influent/effluent solids/sludge streams, butthe column headings do not clearly identify these streams. Add a column statingwhether the stream is influent or effluent, and clarifyunits for solid/sludgestreams (tons/day of solids or gallons per day flow rate).n. Residence time and life of impoundment varies depending on the state of theunit, when it was last dredged, etc. Q. D3-1 alone may cause detailed surveys tobe performed. EPA should define “residence time.”o. Many of these impoundments were designed and built over30 years ago.Design information requested in D3-2 will be very difficultto find and may notexist at all.p. Q. D3-2, Q. D3-3, and Q. D3-4 should be revised because the maximumpond/impoundment depth for some facilities may include a requirement tomaintain a certain minimum level of freeboard below the top of the embankment.q. Maximum current depth data requested in Q. D3-3 may not beavailablewithout taking field measurements from a boat! EPA should not requireresponders to generate new data specifically for this questionnairestudies.i. EPA stated in the instructions that Section 2 should becompleted for eachpond/impoundment system or wastewater treatment system identified inTables D-1 and D-2. These tables are limited to systems that treat wastewatersfrom ash or FGD operations.j. EPA did not remove the block diagram requirement, because it is standardand necessary. EPA recognizes that the survey requests more information thanwhat is used for permit requirements; however, the overall burden of thisquestion is lessened by only requiring block diagrams for treatment systems ofinterest, not all treatment systems. Additionally, due tothe timing of the ICRmail-out, 2009 data will be available. EPA also clarified in the 5th item of theblock diagram checklist to explain that the destinations should be "general"and that codes should be used from the “Code Tables” tab.k. EPA recognizes that some flow rates requested may not be monitored.Therefore, plants should provide their best estimates.l. EPA included the process codes in the dropdown boxes inthe 2ndFRNversion of the questionnaire. EPA also added a “Code Tables” tab at the endof each part for reference.m. EPA revised this table by making it specific to influent streams, and addeda second table for effluent streams. In addition, EPA specified units forsolid/sludge streams in tons per day or gallons per minute.n. EPA rephrased Q. D3-1 to ask for "residence time (as currently operated)."o. EPA is aware that it may be difficult to obtain design information for pondsthat were built over 30 years ago, however, respondents should use the bestavailable data to respond to the questions. Respondents should use thecomments page to explain any estimates or assumptions made for therequested information.p. EPA added a specific request for freeboard height and removed the requestfrom Part F of the questionnaire. EPA also provided a genericpond/impoundment diagram to show the depth and other dimensions ofpond/impoundments.q. EPA clarified in Q. D3-3 that plants are not required totake newPage 29 of 39Version: February 22, 2010CommentResponser. The information requested in Q. D3-6 should be limitedto the last three years.Requiring information beyond the last three years is overly burdensome, willneedlessly increase the time necessary to respond tothis question, and is unlikelyto provide information that is more representative thaninformation for the lastthree years.s. Q. D3-9, Q. D3-19, and Q. D3-21 are very open-ended questions that willproduce inconsistent answers.t. Clarify what should be included and excluded when calculatingcosts in Q. D3-9. For example, should labor costs be included?u. Commenters suggests that the check boxes should include a“none or N/A”choice for Q. D3-10. In addition, commenters suggest rewording the question tostate "using techniques other than solely settling" for clarification.v. In Q. D3-12 and Q. D4-10, it may be necessary to provide chemical dosages asyearly estimates. In addition, the questions request concentration of treatmentchemicals in the treatment unit in g/L, as well as theaddition rate in gpm. For alot of chemicals, such as liquid polymer or ferric chloride, the plant will knowgpd fed and ppm by volume. g/L may apply to a dry feed systemsuch as lime.Clarify to give the option for solid chemicals to useg/L, or for liquid reagents toreport in gph.w. Commenters expressed concern with Q. D3-13 through Q. D3-15stating thatthe request for all closed units is extremely broad. Information for closed unitsmay not be readily available. The request should be limited to units closed withinthe last 3 years. The request should also exclude units forwhich the solids whereremoved (e.g., “clean” closed) prior to closure and for units that were replacedin-kind. Commenters also feel that EPA does need the original dimensions of aclosed pond. It was also stated that Q. D3-15 should be revised to require themaximum depth based on the final elevation of the wastewithin the pond orimpoundment, not the height of the berm because the final elevation constitutesthe final maximum depth. EPA should also request the quantity of solids thatwent into the pond over the life of the pond/impoundment.x. In Q. D3-20, why does EPA need the closure plan, if any,for a closed pond?This is excessive, especially since EPA asks in the next question for a summaryof the steps of closure and closure costs.measurements to provide this data; however, best available information shouldbe used to answer this question.r. EPA already had limited the bulk of this question (frequency, duration, andvolume dredged) to the last five years. EPA does not believe it is necessary tolimit the request for the year of last dredging, frequency of dredging that year,and amount of material removed that year to the last three years since someponds/impoundments (perhaps many or even most ponds/impoundments) havenot been dredged within the last three years.s. EPA phrased these questions in this manner to provide plants the flexibilityneeded to provide the information requested.t. EPA revised Q. D3-9 instructions to clarify the cost request..u. EPA added a "NA" response option to accommodate any pondsthat don'thave "techniques other than settling." EPA also revised the question by adding“solely settling (e.g., adding chemicals to remove certain metals)”.v. EPA clarified in Q. D3-12 and Q. D4-10 that plants should provide thechemical dosage response in gpd and, if necessary, the plants can divide thetotal yearly chemical dosage by the number of days addedthroughout the year.EPA also revised the "Average Addition Rate" column to allow for both gpdand pounds per day options.w. EPA revised Q. D3-13 through D3-15 to limit the number ofyears forinformation regarding closed pond/impoundment units to the last 10 years tolessen the burden on the industry and still receive the information necessaryfor the rulemaking. EPA revised Q. D3-15 to request thepond/impoundmentunit's volume, surface area, bottom and top elevation, freeboard height,maximum height of berms and dams above the surrounding grade, and thetotal quantity of solids placed in the pond/impoundment when it was originallybuilt and at its end of life. EPA also added the requestfor the quantity of solidsthat went to the pond over the life of the pond.x. EPA requests the closing plan and associated cost information to evaluatethe option of converting wet ash handling systems to dry. EPA rephrased Q.D3-21 to explain that if the plants have provided a closure plan that describesthe closure process, the required steps, and the totalcapital and O&M costsassociated with the closure, that they do not need to respond to D3-21.Page 30 of 39Version: February 22, 2010CommentResponsey. Q. D3-21 as currently worded is very broad and likelywill result in thegathering and provision of information that does not aidin the potentialrulemaking process.z. Are UICs considered wastewater treatment systemsfor purposes of Section 4?aa. Design, average 2009, and maximum 2009 flow rates are requested.Recommend adding average and maximum period for consistent responses (i.e.,annual average, maximum daily flow).bb. Q. D4-3 should be deleted from the Questionnaire. Respondents should notbe required to provide bid proposals for wastewater treatment systems. Bidproposals are not reliable information, as they are merely estimates of anticipatedcosts. Also, bid proposals may be influenced by the working relationshipsbetween the parties. Bid proposals also do not normallyinclude the balance ofancillary equipment or installations, such as interconnecting pipes and controls.EPA should focus instead on actual installed systems. Best estimates for totalcapital and O&M costs would be more appropriate requests,yield better qualityinformation, and less burdensome.cc. Commenters stated that since EPA requires submittalof the current NPDESpermit and several system diagrams, EPA should refer tothe permit and thediagrams for the effluent limitations applicable to thewastewater treatment unitand its discharge, instead of asking Q. D4-7.dd. Replace column heading “2006 Annual Cost” with “2009 Annual Cost” inTable D-10.ee. In Q. D5-1/Table D-10, EPA does not provide instructions for determiningwhat rate per kilowatt hour to use for power for pumping and power foroperations other than pumping. Also, the individual O&M categories identifiedin Table D-10 are too specific. EPA should generalize these costs and allowrespondents to provide the total O&M costs for the questionnaire.ff. Q. D5-2 requests capital costs for wastewater treatment systems. In manycases these systems may have been installed 25 to 50 years ago. Collectingrecords of capital costs from that long ago could be extremely burdensome. Also,The individual capital costs identified in Table D-11 are too specific. Werecommend specifying the types of direct and indirect capital costs to beconsidered in the description for clarification and requesting only the total capitaly. EPA phrased these questions in this manner to provide plants the flexibilityneeded to provide the information requested.z. For the purpose of the questionnaire, UICs are NOT considered treatment,they are considered disposal.aa. EPA revised this question to request maximum design flow rate andmaximum daily flow (in gpd).bb. EPA recognizes the limitations of system/cost information in bidproposals/engineering reports; however EPA did not removeQ. D4-3, becausethe bid proposals/engineering reports provide useful information to fill datagaps, particularly for planned wastewater treatment systems.cc. EPA is aware that certain wastewater treatment systems may achievespecified effluent limits for different pollutants; however, this information isbeing requested to determine if there are certain pollutant(s) that drive theoverall treatment system operation. This may not always correspond to thepermitted limitations.dd. EPA incorporated these changes.ee. EPA added an explanation to Table D-10 to clarify thatplants may use thetotal kWh used for pumping (for the treatment system) in2009 to estimate$/kWh for pumping costs. Similarly, for $/pound steam costs, plants may usethe total pounds of steam used (for the treatment system) in 2009. The O&Mcost breakouts will allow EPA to most accurately comparecosts for treatmentsystems in the industry. EPA expects plants to provide information to the bestof their ability, providing estimates if necessary. Estimated responses shouldbe noted in the Comments page.ff. EPA revised Q. D5-1 and Q. D5-2, only request information for systemsinstalled in the past 25 years. The capital cost breakouts will allow EPA tomost accurately compare costs for treatment systems in the industry. EPAexpects plants to provide information to the best of their ability, providingestimates if necessary. Estimated responses should be noted in the Commentspage.Page 31 of 39Version: February 22, 2010CommentResponsecost and year on which the cost is based. Simplifying therequest will minimizethe time necessary to gather more specific information.Part E/Wastes from Cleaning Metal Processing Equipmenta. Revise Q. E1-1 and E1-2 to request information on generation of wastes since2007 instead of 2000.b. Facilities that ship all metal cleaning wastes to off site treatment or disposalshould be exempt from answering Part E.c. Clarify definitions of the terms “episode” and “residues.”d. Revise Q. E1-2 instructions: “an” should be “on.”e. One commenter suggested that Table E-1 should be split into two separatetables, one for cleanings using chemicals and one for cleanings withoutchemicals. Many commenters also requested that the seventh column in Table E1 be modified to allow reporting of volume by cleaning event instead of annuallyand the eighth column be revised to request the frequency ofcleaning events.f. Q. E1-3 is a very open-ended question and it will result in inconsistentanswers.g. Q. E1-4 should include evaporation as a response option.h. Q. E1-8 asks for a waste determination status that may not be known until thewastes are generated and sampled. The results of the testing may determinewhether the wastes are hazardous or non-hazardous.a. EPA has revised this question to request information about the most recentcleaning event for each cleaning operation with chemicaladdition and withoutchemical addition on metal process equipment that has occurred since January1, 2000. EPA is aware that some cleaning operations may occur years apartand does not want to risk mischaracterizing the industrieswastewatergeneration by limiting the duration of the question.b. EPA does not agree to exempt facilities that ship these wastes off site fromanswering the questionnaire. EPA has already limited this part of thequestionnaire to a statistical subset and therefore requires complete answersfrom all respondents in order to characterize national practices.c. EPA replaced the term “episode” with “cleaning event”and defined the termin the instructions of Q. E1-2. EPA also defined the term “residue” in thequestionnaire glossary.d. EPA incorporated these changes.e. EPA incorporated these changes.f. EPA recognizes that close-ended questions are preferable. However, inorder to provide plants the flexibility necessary to provide the informationrequested, EPA has retained the format for this question.g. EPA incorporated these changes.h. EPA has revised this question to provide a more typicalanswer that does notrequire sampling data.Part F/Management Practices for Ponds/Impoundments and Landfillsa. Revise Section 1 to also apply to oil.b. Are ponds/impoundments that perform treatment included inSection 1 and 3?c. In Q. F1-5, “storms in close succession” should be defined. The Agency couldget many varied responses unless some definition of size,frequency, and/orduration is not requested. Also, EPA should define what itmeans by a “designa. EPA did not revise Section 1 to also apply to oilin order to minimize burdenand because the combustion of oil is not the focus of this part.b. EPA reworded the instructions of Section 1 and 3 toinclude“pond/impoundment units or landfills used for the storage, treatment, and/ordisposal of residuals or by-products...."Page 32 of 39Version: February 22, 2010CommentResponsestorm.”d. Commenters stated that ponds and impoundments typicallydo not haveleachate collection systems. However, units with singleand double liners mayhave a leak detection system from which water can be removed and treated.Commenters also requested that EPA define the terms “leak detection system”and “leachate collection system” in order for respondentsto give an accuratereply.e. Q. F1-8 and Q. F2-9 assumes plants have monitoring controls to determine thenumber of days leachate is collected, however all plants may not have monitoringcontrols. Add a sub-question regarding estimate method (e.g., pumping logs,flow meters, and engineering judgment).f. Q. F1-12 through Q. F1-15 are redundant with the USEPA AshManagementUnit Survey questions and Q. F3-3 is redundant with the April 2009 questionfrom the House Committee on Transportation and Infrastructure's Subcommitteeon Water Resources and Environment.g. The fourth question in Q. F1-9, Q. F2-10, and Q. F2-15 requests the treatmentsystem ID from Table A-4, but Table A-4 is intended to list pond/impoundmentareas, not treatment systems. Correct the table reference.h. Q. F1-10, Q. F2-12, and Q. F2-16 do not specify how much leachate isrecycled back in the plant. For leachate recycled back into the plant, request anestimate of the amount reused (as a percent of total).i. Many commenters expressed concern about the request for the cost ofcorrective actions, cost of inspection, and qualifications of the inspector in TableF-1. Commenters stated that the cost of corrective actions will already beincluded in the total O&M costs for each unit, that it will be difficult to estimatethe cost without conducting engineering studies, and that the table requiresfurther clarification of what should be included and excludedwhen calculatingthe cost. Commenters also stated that the request forthe qualifications of theinspector goes beyond the scope of the questionnaire and thatmost inspectors donot have construction experience. Additionally, it was requested that a footnotebe added to the “cost of inspection” column to require therespondent to indicateif the inspection was self-performed.j. Q. F2-1 should be rephrased. Not all landfills are “licensed,” in the sense thatc. EPA revised Q. F1-5 to ask if the pond/impoundment unit haseverexperienced an overflow, excluding routine permitted discharges and added anew question to ask if such overflow was discharged to a receiving waterd. EPA revised the definition of the term “leachate” toinclude leakage, leak,seepage, leachate collection, and leak detection sources.EPA also defined theterms "leak detection system" and "leachate collectionsystem" in the glossaryof the questionnaire.e. EPA clarified that the plants should provide a description of the estimationmethod in the “Part F Comments” tab at the end of PartF.f. EPA has generally retained Q. F1-12, Q. F1-13, and Q. F1-15/Table F-1.However, EPA deleted Q. F1-14 and removed the "Qualificationsof theInspector" and “Findings of Inspection” columns in Table F-1. Additionally,EPA did not remove Q. F3-3 because it does not request groundwatermonitoring data; therefore, the question does not contribute significantly to theburden.g. EPA revised the question to refer to Table D-2 instead of Table A-4.h. EPA did not incorporate these changes because the percent recycled is notabsolutely necessary to evaluate option for the ELG revisions and EPA felt thismay be overly burdensome.i. In Table F-1, EPA did not remove the “cost of corrective actions” columnbecause the questionnaire only requests the total O&M costs for 2009.However, EPA provided additional clarification of what should be included inthe cost of corrective actions (e.g., labor costs).,EPA also recognizes thatproviding this information may be more difficult without conductingengineering studies for those corrective actions thathave not yet been taken,and in these instances plants should provide their best estimates and anynecessary comments in the Comments tab. Engineering studies would not benecessary for those corrective actions which have already been implemented.In addition, EPA removed the “qualifications of inspector” column from thetable, as noted above. However, EPA did not add a footnote, but renamed the“Company/Consultant Name” column to “Affiliation of Inspector,” which hasthe respondent specify if the inspector was a plant/companyemployee or aconsultant. Additionally, EPA revised the instructions toclarify thatestimating the cost for on site or company personnel to conduct inspections isPage 33 of 39Version: February 22, 2010CommentResponsethe state provides an official license. In some states, while the state reviews andapproves design plans, it does not issue a license.k. In Q. F2-5 clarify what should be included and excluded whencalculatingcosts.l. In Q. F2-5, include the date of the expansion, specifywhat dimensions arerequired, and request information on future plans to expand.m. In Q. F2-12 further define the term “discharged” to clarify if this is meansthrough a NPDES permitted outfall.n. In Q. F2-14 “Conveyance for stormwater run-off from the landfill” suggestsall stormwater has contacted active surfaces of the landfill and does notdistinguish between stormwater from capped areas of the landfill versus runofffrom non-capped areas. Clarify that this is water thatdoes not contact solids(assumes any water contacting an uncovered, working face would becomeleachate).o. EPA’s instructions for Section 2refer to on site landfills previously defined inTable A-6. Table A-6 includes operating/active, retired/closed, and plannedlandfills. Section 2 questions seem to be directed toward operating/activelandfills. Landfill characteristics/design for planned landfills may not beavailable or may change prior to construction.p. The checkbox for “No” in Q. F3-1 needs a (Skip to End ofSection F)instruction.q. Q. F3-3 could be interpreted differently depending on thedefinition ofpollutant (e.g., is calcium a pollutant), and background (e.g. a well upgradient ofthe landfill / pond or a regional background computed as in a RCRA study).Clarify the terms "pollutants" and "background".r. Commenters expressed concern about the relevancy of section 3 and requestedthe removal of these questions. Commenters also requested that the section beapplicable to pond/impoundment systems, wastewater treatment systems, andlandfills rather than specific pond/impoundment units andthat EPA shouldspecify if Q. F3-3 is focused on ash related constituents and/or on agriculturalrelated compounds.based on their labor costs and time involved.j. EPA replaced the term “licensed volume” with “approved/licensed volume”in Q. F2-1.k. EPA clarified that the costs requested in Q. F2-5 should include any labor,materials, and energy costs. In addition, EPA also stated that any uniquecapital costs should be listed separately from the general costs associated withexpansion.l. EPA clarified that the dimensions refer to surface area, volume of storedmaterials, and height and added a request to provide thedate(s) of expansion.However, EPA did not find it necessary to include a request about futureexpansions.m. EPA reworded the response options throughout this part to specify the typeof discharge, either to a POTW or discharged directly (and to specify theoutfall number).n. In revising the questionnaire, EPA has differentiated between capped anduncapped portions of the landfill.o. EPA revised the instructions throughout Part F to require the respondent tocomplete this part for all active/inactive/open and retired/closedpond/impoundment units and landfills.p. EPA added “Continue to Question F3-2” next to the “yes” response optionand added “Skip to next Questionnaire Part” next to the “no”response option.q. In Q. F3-3 EPA clarified the term “pollutant” for the purpose of the questionby referring to a list of analytes in Part G. EPA defined the term “backgroundconcentration” for the purpose of the ICR in the glossary.r. EPA did not remove Section 3, because the groundwater monitoringinformation is requested to evaluate the industry-wide prevalence ofgroundwater monitoring practices and to help evaluate the potential of leachatecontaminating surface waters. However, EPA clarified that Q. F3-3 is limitedto pollutant concentrations from ash and FGD related constituents and revisedSection 3 to request the information on a pond system level (referring to TableD-1, D-2, or A-6).Page 34 of 39Version: February 22, 2010CommentResponsePart G/Leachate Sampling Data for Ponds/Impoundments and Landfillsa. Include analyses of TSS, sulfates, dissolved metals, and dissolved mercury.b. Leachate streams from landfills are already regulatedthrough state solid wastelaws in most jurisdictions. Therefore, further regulation of leachate from coalcombustion landfills may not be necessary, and EPA shouldn’t prejudge theissue.c. Many commenters stated that it does not make sense to ask for leachate datafrom a pond or impoundment, because ponds/impoundments typically do nothave leachate collection systems. However, units with single and double linersmay have leak detection systems from which water can be removed and treatedand therefore, it is unclear if the intent of this request includes water collectedfrom leak detection systems. Additionally, commenters requested definitions forthe terms “leachate,” “runoff,” “untreated,” “treated,” and “detection limit.”d. If the respondent answers “no” to Q. G1-2, there should be an instruction toskip to Q. G1-5.e. Multiple commenters stated that many of the facilities will not be able toaccomplish the leachate sample collection in the requiredamount of time,because some facilities do not regularly generate leachate weekly and there are alimited number of labs that are certified to collectand analyze the samples bylow-level methods (e.g., Method 1631E). Therefore, everyfacility chosen for thesample collection will need to have their collectionand analysis completed at thesame time, which could prove to be impossible during a short window of time.f. Facilities that collect and dispose of leachate offsite (i.e., not discharged)should be exempt from the sampling requirement, as the information collectedlikely would not be representative of typical leachatedischarges.g. Clarify if pond/impoundments that perform treatment are included in this part.h. The costs for collecting and analyzing eight samplesof leachate (treated anduntreated) per treatment unit will be significant. Onecommenter estimated thatthe costs for collection and laboratory analysis persample are in the range of$1,000 to $1,500. Therefore, the costs will be especiallyhigh for facilities thatwill be required to collect both untreated and treated samples. In addition, theburden will be very large for small facilities that arefrequently on very tightbudgets.a. EPA added analyses of TSS and sulfates; however, EPA didnot adddissolved metals and dissolved mercury, because of the additional burden(including cost) associated with the sample collection andanalysis.b. EPA has not prejudged this issue, but requires additional data to determineif revisions to the ELGs are necessary for leachatedischarges.c. EPA defined the term “leachate” in the questionnaire glossary to includeleakage, leak, seepage, leachate collection, and leak detection sources. EPAalso defined the terms “treated” and “detection limit”in the questionnaireglossary and clarified the difference between untreated andtreated leachate inthe leachate sample collection instructions.d. EPA has now included skip instructions for this question.e. EPA revised the instructions of the leachate samplecollection to collectleachate samples every week for four weeks or as soon thereafter as sufficientleachate is available for collection, therefore collection during consecutiveweeks may not happen in all cases. Laboratory availability is not expected tobe a problem because of the small number of samples that will be collectedand analyzed, relative to the number of samples laboratories routinely analyzenationwide from a variety of facilities, even when considering the specificanalytical methods required by the ICR. The holding time for EPA Method1631E is 90 days; therefore, samples will not need to be analyzed immediatelyupon collection. This will allow labs ample time to receive and preservesamples in order to handle the required analyses within thetimeframeprovided.f. Even those plants that send leachate off-site are required to provide samplingdata for untreated leachate because the data will be usedto characterize theraw wastewater and evaluate treatment technology for revised ELGs.However, EPA has revised the instructions to clarify thatfacilities that collectand dispose of leachate off site are not required to provide sampling data fortreated leachate; only facilities that treat leachate onsite are required toprovide treated data.g. EPA clarified in the instructions that pond/impoundmentsthat performtreatment are included in this part.Page 35 of 39Version: February 22, 2010CommentResponsei. EPA should develop a screener questionnaire that would allow EPA toinvestigate all potential analytical issues with the leachate matrices anddetermine whether any further existing data or samplingwould be beneficial forcharacterizing leachate discharges.j. EPA should consider allowing the submittal of historic leachate data, ifavailable, instead of requiring four new and additional weekly leachate sampleresults.k. Many commenters expressed concern that EPA’s instructions for sampling arenot clear. EPA does not specify where to sample for untreated or treatedleachate, and therefore the resulting data will be inconsistent.l. Depending on the characteristics of the leachate samples, Method 200.8 may bean inappropriate choice for some metals. It has been demonstrated that Method200.8 can produce erroneous results for some metals in certain matrices due topolyatomic interferences. These interferences can result in erroneous analyticalresults.m. EPA should require rainfall information (in inches per day) for 30 days priorto the first leachate sampling, and also during the entiresampling period.n. Depending on the configuration of the leachate collection system, samplingmay be difficult due to confined space entry issues (i.e.,in manholes). Theremay be significant safety concerns at some facilities due to this samplingrequirement.o. Q. G1-6 is duplicative of Tables A-5 and A-7. The respondent alreadyidentifies types of wastes in each management unit on thosetables. EPA shouldrefer to those answers and not ask for the same information twice. In addition,EPA should clarify that the amount of waste requested inQ. G1-6 applies to theuncapped portion of landfill that contributes to leachate.h.. EPA estimated in the supporting statement that the cost to analyze oneleachate sample at one sample location (taking into account analytical testing,supply costs, and sample collection labor) would cost $2,212.55, which issignificantly higher than each of the commenters’ estimates. Depending onwhether a plant has a pond, a landfill, or both, EPA hasestimated anywherefrom 4 to 16 sample points at a plant. Therefore, EPA hasaccounted for theburden associated with this sampling effort. However, to reduce burden onsmall entities, EPA has excluded them from the subset ofcoal-fired plantsselected to respond to Parts E, F, and G (and thus is excluding them fromsampling).i. EPA does not agree that a screener questionnaire is necessary for the purposeof investigating analytical issues for leachate.j. EPA revised the leachate sample collection instructions to allow a plant toprovide existing data in lieu of collecting new data ifthe historic data fulfillsthe specific requirements articulated in Part G.k. EPA revised the leachate sample collection instructions to clarify that theplant should collect samples from each leachate collection point for eachpond/impoundment and landfill. If the plant determines that a sample from oneor more collection points are representative of an individualpond/impoundment or landfill, then the plant may simply collect therepresentative sample(s) instead of sampling each collection point.l. Method 200.8 is an EPA-approved method and therefore isvalid for settingeffluent limitations. It remains the required analyticalmethod for selectedanalytes; however, EPA has added flexibility for alternative methods forcertain parameters.m. EPA added a question requiring rainfall information fortwo weeks prior toand throughout the sampling period, because the amount of rainfall can impactcharacterization and the amount of leachate generated.n. EPA recognizes there could be safety issues associatedwith leachatesampling; therefore, EPA revised the instructions of the leachate samplecollection to allow the plant to request exemption from the data collectionthrough the submittal of a written request within two weeks after receiving thequestionnaire. The submittal must explain why the plant is unable to collectPage 36 of 39Version: February 22, 2010CommentResponsethe samples safely.o. EPA has revised the request, but still retains the request for types of wastesin each management unit because Part G requests the amountsof each type ofwaste, whereas Part A simply asks what type of wastesare managed. Inaddition, EPA revised Q. G1-6 to request the plant to complete two rows inTable G-3 if the landfill is partially capped, one for the amount of waste underthe capped portion of the landfill and one for the amountof waste under theuncapped portion of the landfill.Part H/Nuclear Power Generationa. Several of the questions within Part H refer to “water streams,” while othersrefer to “wastewater streams.” Commenters believe these terms should bedefined.b. Commenters believe Q. H1-2 is not necessary. The type of nuclear unit is notlater correlated to specific waste streams.c. Commenters believe that the term “associated withthe nuclear generatingunits” should be defined. They question whether this only includes streamsdirectly associated with the nuclear reactor, or if itincludes all streams associatedwith the generation of electricity. Additionally, they ask whether streams notassociated with electricity generation should be included(potable water, sewage,fire protection, car washes, etc.)?d. Commenters believe the electronic version of theQuestionnaire needs to allowfor more than four entries on Table H-1 Also guidance should be provided fordescribing the “type of water stream.” Commenters arenot certain whether this ismeant to be a simple description using existing Effluent Guideline descriptions(low volume wastes, chemical cleaning wastes, etc.) or if each facility shoulddevelop unique descriptors.e. Commenters believe it would be problematic to answer Q. H2-1 for nonroutine, intermittent streams. Some of these waste streams may go years betweendischarge events.f. Commenters believe Q. H2-2 should include a response box for “dischargedwith treatment” and replace “All leachate discharged” to“All treated waterdischarged.” Additionally, the choices for destinations oftreated water in Q. H2-3 include leachate and sluice water, both of which do not exist at nucleara. EPA replaced the term “wastewater streams” and “water streams” with“process wastewater.” EPA added and defined the term “process wastewater”in the glossary of the questionnaire.b. EPA deleted Q. H1-2 from the questionnaire since this information can bereceived from NRC. However, EPA does request the type of nuclear unit inthe “Type of Boiler or Reactor” column in Table A-10 (planned systems).c. EPA has revised the wording to say “associated with the production ofelectricity from nuclear generating units” and expects respondents to report allprocess wastewater associated with running the nuclear plant. EPA alsoupdated the definition of “process wastewater” to ensurethat plants are notincluding non-contact cooling water, sanitary water, uncontaminated stormwater, portable water, sewage, fire protection, or car washes.d. The electronic version of the questionnaire allows for 36 entries. EPArevised the table by including a drop down box with specific processwastewater streams identified, including an "other" category where the plantcan define any additional streams not already identified.e. EPA revised Q. H2-1 to allow plants to provide data on both continuous andintermittent streams.f. EPA combined Q. H2-2 and H2-3 and revised the response options for thequestion so that they were applicable to nuclear plants. This included removingthe use of the term “leachate.”Page 37 of 39Version: February 22, 2010CommentResponsefacilities. EPA should modify this question to remove these response boxes.Part I/Economic and Financial Dataa. Several commenters noted the challenge of coordinating responses fromplant’s having multiple owners, expressing concerns with both the limited timeprovided to complete the questionnaire and the utility of collecting detailedinformation from each owner.b. Commenters noted that certain terms used in the questionnaire refer toconcepts that are not accurate legal descriptions of theplants’ ownershipstructuresc. One commenter questioned the utility of asking for total revenue and totalemployment rather than focusing strictly on revenue or employment associateddirectly with electricity generation.d. Several commenters questioned the utility of asking fordata on activities notdirectly related to electricity generation.e. Commenters noted that this information is not currently compiled undercustomary business practice and completing the questionnaire would thereforeimpose a significant burden on respondents.f. Commenters questioned the utility of asking for information about the overalloperations of the ultimate parent rather than focusing only on electricitygeneration.g. Commenters asked for clarification of the activities included in “revenuegenerating activities other than generation of electricity.”h. Commenters also questioned the purpose of asking for other revenue inQuestion I1-30 and suggested deleting this row from the table.i. One commenter asked for clarifications on how variable O&M costs should bedetermined for the purpose of this questionnairea. In response to the comments, EPA has clarified the instructions to clarifythat it seeks detailed information (balance sheet, income statement, etc.) onlyfrom the owner that has the largest ownership share or financial interest in thesteam electric capacity at the plant. Only summary information (revenue,number of employees and identity of the ultimate parent)is requested for otherowners. This summary information is expected to be easierto gather and willbe used to assess the potential for substantial economic impacts on entities thatown or have another form of financial interest in steam electric plants,including in identifying entities that meet the definition of a “small business.”Regarding the logistics of coordinating responses among multipleowners,EPA has designed the questionnaire to be modular and to alloweach section tobe completed by different individuals, as needed, prior tobeing returned toEPA.b. EPA recognizes that plants can have types of ownership structures thatdiffer from a partnership or joint venture. In responseto the comment, EPAhas revised the instructions and the definitions provided in the glossary tobroaden the concept of ownership to also include otherforms of “financialparticipation or interest”. The simple term “plant owner”suggested in onecomment is general and is captured by the concept of immediate parentdescribed in the revised questionnaire and glossary.c. The intent of this question is to help determine entitysize according to theSmall Business Administration (SBA) standards for the analyses required bythe Regulatory Flexibility Act (RFA) and the Unfunded Mandates Reform Act(UMRA) if the immediate parent is also the ultimate parent. This question wasasked at the immediate parent- as well as the ultimate parent-level to simplifythe skip pattern for questions. For the purpose of size determination, EPAneedstotalrevenue, employment, and electricity sales, as opposed to onlythose related to steam electric operations. EPA is asking for revenue andemployment associated with electricity generation for every immediate parentto allow the eventual assessment of the uncertainty associated with attributingcompliance costs and other impacts only to immediate parent owner (largestequity share) and to support a cost-to-revenue analysis ofimpacts to allPage 38 of 39Version: February 22, 2010CommentResponseaffected entities.d. The intent of this question is to determine the scope ofbusiness activities ofthe immediate parent including those activities aside fromelectricitygeneration as well as the relative importance of theseother business activitieswith respect to profitability of the firm. EPA will usethe information tosupport the regulatory cost impact.Based on the comments, EPA has revised the question to distinguish between(1) production activities that are electricity generation-dependent, such as saleof steam or ash, waste combustion (which depend directlyupon the generationof electricity) and (2) production activities that are notelectricity generationdependent, such as leasing of land. EPA has also revised the instructions tospecify that, in this section, it is asking for information regarding all operationsof the immediate parent and not just those of the plant,as these are covered inseparate questions.e. In response to these comments, EPA has modified the two questions toreduce respondent burden to the extent possible while getting the data neededto conduct analyses. The questions have been revised to clarify the informationrequested, to specify that approximate shares are sufficient for the purpose ofthis data collection, and to explain that respondents need not review individualcontracts to determine the exact fraction of sales subject to different pricingconditions. EPA expects that respondents will already have a sense of theapproximate share of electricity sold under different terms, even if they do nothave the exact statistics for each year. Additionally, the Agency has reducedthe number of data items it is requesting by asking for information regardingcontract duration and terms for only the most recentyear of data (2009).While EPA does not expect that respondents will have toconduct an historicalreview of all contracts and their terms, the Agencyhas nonetheless revised itsburden estimate to account for the potentially greater level of effort involved inanswering this question.EPA has also clarified the basis for the shares requested to specify that they bebased on physical quantities (MWh).f. EPA retained this question but explained the purpose forrequesting theinformation in the instructions.Page 39 of 39Version: February 22, 2010CommentResponseThe intent of this question is to help determine entitysize according to theSmall Business Administration (SBA) standards for the analyses required bythe Regulatory Flexibility ACT (RFA) and the Unfunded Mandates ReformAct (UMRA). For the purpose of size determination EPA needs total revenue,employment, and electricity sales, as opposed to only those related to steamoperations.g. EPA has revised the question to specify that activities carried out by thirdparties and for which the plant incurs no cost and receives no revenue shouldnot be included in the response.h. Regarding draft Question I1-30, because information on other plant revenueis already asked for, EPA deleted the row from this question.i. EPA provided a description of variable O&M costs in the glossary.